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...
Refund claim - tax liability discharged by the appellant twice - The verification report of the department itself is supporting the appellant’s contention that the same liability has been discharged twice by the appellant once inadvertently in the inactive account, subsequently, in the active account - no other evidence was required to be produced by the appellant. Otherwise also it is a settled law that onus always rests upon the department to prove the allegations raised in the show cause notice - Refund allowed - AT
Refund claim - tax liability discharged by the appellant twice - The verification report of the department itself is supporting the appellant’s contention that the same liability has been discharged twice by the appellant once inadvertently in the inactive account, subsequently, in the active account - no other evidence was required to be produced by the appellant. Otherwise also it is a settled law that onus always rests upon the department to prove the allegations raised in the show cause notice - Refund allowed - AT
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