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...
Penalty u/s. 270A - GP estimation - underreporting of income - The AO failed to prove underreporting, and the penalty for underreporting of income u/s 270A cannot be imposed based on an estimate. As the addition was made on GP estimation, the penalty is not maintainable, and the AO directed to delete it. - AT
Penalty u/s. 270A - GP estimation - underreporting of income - The AO failed to prove underreporting, and the penalty for underreporting of income u/s 270A cannot be imposed based on an estimate. As the addition was made on GP estimation, the penalty is not maintainable, and the AO directed to delete it. - AT
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