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...
Disallowance of Expenses - AO erred in appreciating that nonreply of Section 133(6) notices cannot necessarily lead to disallowance of petty expenses ranging from Rs. 9,000/- to Rs. 1,00,000/- in the absence of any other proof of non-incurring of expenses. Assessee has provided primary and direct evidences along with the PAN & address and hence, no disallowance can be made merely on the reason of noncompliance of the parties to the notices issued u/s 133(6) of the Act. - AT
Disallowance of Expenses - AO erred in appreciating that nonreply of Section 133(6) notices cannot necessarily lead to disallowance of petty expenses ranging from Rs. 9,000/- to Rs. 1,00,000/- in the absence of any other proof of non-incurring of expenses. Assessee has provided primary and direct evidences along with the PAN & address and hence, no disallowance can be made merely on the reason of noncompliance of the parties to the notices issued u/s 133(6) of the Act. - AT
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