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...
Revision u/s 263 - Bogus expenditure towards sub-contract payments made to persons who were previously employed in the assessee’s company as supervisors / garage in-charge for monthly salaries - The Tribunal observed that the AO did not examine payments to subcontractors during assessment proceedings. - The details of sub-contracts were not verified, and claims by the assessee were accepted without inquiry. - The ITAT found the AO's actions to be erroneous and prejudicial to revenue. - Hence, the proceedings under section 263 were rightly initiated.
Revision u/s 263 - Bogus expenditure towards sub-contract payments made to persons who were previously employed in the assessee’s company as supervisors / garage in-charge for monthly salaries - The Tribunal observed that the AO did not examine payments to subcontractors during assessment proceedings. - The details of sub-contracts were not verified, and claims by the assessee were accepted without inquiry. - The ITAT found the AO's actions to be erroneous and prejudicial to revenue. - Hence, the proceedings under section 263 were rightly initiated.
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TaxTMI 
TaxTMI 
of 4897 
