SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Revision u/s 264 - payment of tax on FTS under the DTAA at wrong rate (20% instead 10%) - it is not even denied by the Department that the Petitioner committed a mistake and should have paid tax at 10% - extra 10% paid by the Petitioner was of its own volition, it was indeed prejudicial to the Assessee - all the ingredients of Section 264 stand attracted hence permissible
Revision u/s 264 - payment of tax on FTS under the DTAA at wrong rate (20% instead 10%) - it is not even denied by the Department that the Petitioner committed a mistake and should have paid tax at 10% - extra 10% paid by the Petitioner was of its own volition, it was indeed prejudicial to the Assessee - all the ingredients of Section 264 stand attracted hence permissible
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
