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...
Validity of Revision u/s 263 - Even if it were to be accepted that the assessment has been completed by mere reference to the provisions of section 44AD by the AO, even then, in our view Principal CIT was correct in observing that reference could not have been drawn to the said provisions as the total quantum of transaction was exceeding Rs. 60 lacs in the year under consideration. - Revision order sustained - AT
Validity of Revision u/s 263 - Even if it were to be accepted that the assessment has been completed by mere reference to the provisions of section 44AD by the AO, even then, in our view Principal CIT was correct in observing that reference could not have been drawn to the said provisions as the total quantum of transaction was exceeding Rs. 60 lacs in the year under consideration. - Revision order sustained - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
