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...
Revisional jurisdiction u/s 264 - Application u/s 264 rejected as intimation u/s 143(1) of the Act is not an order amenable to revisional jurisdiction u/s 264 - The court ruled that intimation under Section 143(1) is amenable to revisional jurisdiction under Section 264 of the Act. This was based on precedent in "Diwaker Tripathi v. Principal Commissioner of Income tax – 17 & Ors.", which allowed for such revision.
Revisional jurisdiction u/s 264 - Application u/s 264 rejected as intimation u/s 143(1) of the Act is not an order amenable to revisional jurisdiction u/s 264 - The court ruled that intimation under Section 143(1) is amenable to revisional jurisdiction under Section 264 of the Act. This was based on precedent in "Diwaker Tripathi v. Principal Commissioner of Income tax – 17 & Ors.", which allowed for such revision.
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