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...
Writ petition challenging assessment order u/s 147 dismissed. Court held that once assessee has availed alternate remedy of filing appeal, appellate authority bound by jurisdictional High Court's decisions must decide appeal considering assessee's contentions on illegality of assessment order and notice u/s 148 in light of court's interpretation of Sections 151 and 151A. Entertaining writ petitions in such circumstances would require High Court to adjudicate matters pending before appellate authorities, contrary to judicial approach. Assessee directed to pursue pending appeal before appropriate appellate authority.
Writ petition challenging assessment order u/s 147 dismissed. Court held that once assessee has availed alternate remedy of filing appeal, appellate authority bound by jurisdictional High Court's decisions must decide appeal considering assessee's contentions on illegality of assessment order and notice u/s 148 in light of court's interpretation of Sections 151 and 151A. Entertaining writ petitions in such circumstances would require High Court to adjudicate matters pending before appellate authorities, contrary to judicial approach. Assessee directed to pursue pending appeal before appropriate appellate authority.
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