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 HC held that once the petitioner has availed an alternate remedy of filing a substantive appeal, if the assessment order and notices u/ss 148A and 148 are contrary to Sections 151A and 151 as interpreted in Hexaware, the Appellate and Revisionary Authorities, being bound by the jurisdictional HC's decisions, must consider such legal position. The petitioner can raise contentions regarding the illegality of the Section 148 notice before these authorities in light of the Hexaware case. The impugned assessment order shall remain stayed till the Appellate or Revisionary Authority decides the proceedings. The petitioner shall pursue proceedings before CIT(A) against the assessment order and Revisionary Authority, raising contentions on the illegality of the Section 148 notice based on the HC's Hexaware decision.
The HC held that once the petitioner has availed an alternate remedy of filing a substantive appeal, if the assessment order and notices u/ss 148A and 148 are contrary to Sections 151A and 151 as interpreted in Hexaware, the Appellate and Revisionary Authorities, being bound by the jurisdictional HC's decisions, must consider such legal position. The petitioner can raise contentions regarding the illegality of the Section 148 notice before these authorities in light of the Hexaware case. The impugned assessment order shall remain stayed till the Appellate or Revisionary Authority decides the proceedings. The petitioner shall pursue proceedings before CIT(A) against the assessment order and Revisionary Authority, raising contentions on the illegality of the Section 148 notice based on the HC's Hexaware decision.
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TaxTMI 
TaxTMI 
of 4879 
