Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Export income - The expressions “derived from” and “since” are used in multiple instances in the Act. - Deduction u/s 80HHC - Unless the context does not permit, the construction of the expression “derived from” must be consistent. - The strict interpretation is in line with a few relative words, namely, manufacturer, exporter, purchaser of goods, etc. adverted to in Section 80HHC - Including other income as an eligible deduction would be counter-productive to the scope, purpose, and object of Section 80 HHC - Appeal of the assessee dismissed - SC
Export income - The expressions “derived from” and “since” are used in multiple instances in the Act. - Deduction u/s 80HHC - Unless the context does not permit, the construction of the expression “derived from” must be consistent. - The strict interpretation is in line with a few relative words, namely, manufacturer, exporter, purchaser of goods, etc. adverted to in Section 80HHC - Including other income as an eligible deduction would be counter-productive to the scope, purpose, and object of Section 80 HHC - Appeal of the assessee dismissed - SC
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