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...
ITAT allowed the assessee's claim for deduction u/s 80IA for development of infrastructure facilities. It held that merely entering into an agreement with the government or receiving payments from it does not disentitle the assessee from claiming deduction as a "developer" u/s 80IA(4). The assessee's activities qualified as development of new infrastructure facilities, following precedents. The department failed to distinguish the facts from favorable orders of higher authorities for prior years.
ITAT allowed the assessee's claim for deduction u/s 80IA for development of infrastructure facilities. It held that merely entering into an agreement with the government or receiving payments from it does not disentitle the assessee from claiming deduction as a "developer" u/s 80IA(4). The assessee's activities qualified as development of new infrastructure facilities, following precedents. The department failed to distinguish the facts from favorable orders of higher authorities for prior years.
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