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 declined to entertain the petition challenging the Order-in-Original issued by the Principal Commissioner of CGST and Central Excise, Pune. The Court held that no case was made out to deviate from the usual practice of requiring the party to exhaust the alternate statutory appeals available. Regarding the requirement of pre-deposit, the Court observed that the petitioner, being a multi-national company, cannot bypass the alternate remedy on such grounds. However, the Court granted liberty to the petitioner to challenge the notification dated March 31, 2023, if the occasion arises after exhausting the statutory remedies, keeping all contentions of parties open in this regard. The petition was disposed of.
The High Court declined to entertain the petition challenging the Order-in-Original issued by the Principal Commissioner of CGST and Central Excise, Pune. The Court held that no case was made out to deviate from the usual practice of requiring the party to exhaust the alternate statutory appeals available. Regarding the requirement of pre-deposit, the Court observed that the petitioner, being a multi-national company, cannot bypass the alternate remedy on such grounds. However, the Court granted liberty to the petitioner to challenge the notification dated March 31, 2023, if the occasion arises after exhausting the statutory remedies, keeping all contentions of parties open in this regard. The petition was disposed of.
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TaxTMI 
TaxTMI 
of 4879 
