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...
Demanded of interest for the delayed payment of education cess - Education cess and secondary and higher education cess should not be included in the aggregate value for duties on DTA (Domestic Tariff Area) clearances by 100% EOUs (Export Oriented Units). The decision emphasized the principle of not charging a cess on the same tax base more than once, adhering to judicial discipline and the precedential value of the Larger Bench's ruling. - Demand set aside - AT
Demanded of interest for the delayed payment of education cess - Education cess and secondary and higher education cess should not be included in the aggregate value for duties on DTA (Domestic Tariff Area) clearances by 100% EOUs (Export Oriented Units). The decision emphasized the principle of not charging a cess on the same tax base more than once, adhering to judicial discipline and the precedential value of the Larger Bench's ruling. - Demand set aside - AT
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