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...
The High Court upheld the validity of reassessment u/s 153C and rejected the contention of reopening assessment u/s 147. The Assessing Officer relied on the material seized during the search for making additions in the assessees' hands. The Court affirmed the estimation of income on bogus purchases by the Tribunal at 6%, as it concurred with the reasoned decision of the fact-finding authorities. Consistent with similar cases involving accommodation entries, the 6% addition on estimated purchases maintained.
The High Court upheld the validity of reassessment u/s 153C and rejected the contention of reopening assessment u/s 147. The Assessing Officer relied on the material seized during the search for making additions in the assessees' hands. The Court affirmed the estimation of income on bogus purchases by the Tribunal at 6%, as it concurred with the reasoned decision of the fact-finding authorities. Consistent with similar cases involving accommodation entries, the 6% addition on estimated purchases maintained.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
