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...
Violation of principles of natural justice - Mode of Communication - petitioner submits that in most of the cases, the assessees are not aware of the show cause notices and assessment orders due to lack of communication through post - The Court recognized the petitioner's argument regarding the lack of awareness among traders regarding electronic communications. It emphasized the importance of providing adequate opportunity to taxpayers, suggesting that notices should also be issued through postal services and in regional languages to facilitate better understanding and response. - The Court noted the petitioner's assertion regarding the Department's failure to adhere to prescribed procedures. - It emphasized the importance of fair procedures and providing sufficient opportunity to taxpayers before passing adverse orders.
Violation of principles of natural justice - Mode of Communication - petitioner submits that in most of the cases, the assessees are not aware of the show cause notices and assessment orders due to lack of communication through post - The Court recognized the petitioner's argument regarding the lack of awareness among traders regarding electronic communications. It emphasized the importance of providing adequate opportunity to taxpayers, suggesting that notices should also be issued through postal services and in regional languages to facilitate better understanding and response. - The Court noted the petitioner's assertion regarding the Department's failure to adhere to prescribed procedures. - It emphasized the importance of fair procedures and providing sufficient opportunity to taxpayers before passing adverse orders.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
