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...
Deduction u/s 80IB(7A) was denied as income from sale of shop, though built by assessee, was not owned or operated as integral part of multiplex at time of accrual. Assessee lost ownership and operating power over shop, an integral part of multiplex theatre. Contention that similar disallowance was not made in previous year when income was shown under 'Capital Gains' was rejected as no precedent of assessing such income under 'Business income'. Case laws relied upon were held irrelevant.
Deduction u/s 80IB(7A) was denied as income from sale of shop, though built by assessee, was not owned or operated as integral part of multiplex at time of accrual. Assessee lost ownership and operating power over shop, an integral part of multiplex theatre. Contention that similar disallowance was not made in previous year when income was shown under 'Capital Gains' was rejected as no precedent of assessing such income under 'Business income'. Case laws relied upon were held irrelevant.
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