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...
Validity of reopening of assessment - Sanction for issue of notice u/s 151 - The High Court found that the AO had acted based on borrowed satisfaction and lacked independent application of mind. Additionally, the court ruled that the approval granted was merely mechanical and did not involve proper consideration. Consequently, the court upheld the decision of the ITAT to quash the reopening proceedings and notice issued under Section 148 of the Act, dismissing the appeal of the Revenue.
Validity of reopening of assessment - Sanction for issue of notice u/s 151 - The High Court found that the AO had acted based on borrowed satisfaction and lacked independent application of mind. Additionally, the court ruled that the approval granted was merely mechanical and did not involve proper consideration. Consequently, the court upheld the decision of the ITAT to quash the reopening proceedings and notice issued under Section 148 of the Act, dismissing the appeal of the Revenue.
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TaxTMI 
TaxTMI 
of 4888 
