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 263 - Capital gain computation - On both the issues i.e (i). applicability of sec. 50C to the transfer transaction under consideration; and (ii). verification of cost of acquisition/improvement of the property in question, which had been adopted by the A.O as the A.O had failed to make necessary inquiries and verifications, therefore, the Pr. CIT in our considered view had rightly exercised his revisional jurisdiction u/s 263 of the Act.
Revision u/s 263 - Capital gain computation - On both the issues i.e (i). applicability of sec. 50C to the transfer transaction under consideration; and (ii). verification of cost of acquisition/improvement of the property in question, which had been adopted by the A.O as the A.O had failed to make necessary inquiries and verifications, therefore, the Pr. CIT in our considered view had rightly exercised his revisional jurisdiction u/s 263 of the Act.
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