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 additional claim, holding that while the AO may lack jurisdiction to adjudicate an additional claim absent a revised return, the appellate authority possesses jurisdiction to admit such a claim. The Tribunal found prima facie merit in the assessee's contention that she is a not-ordinarily-resident and not a resident, and that certain foreign income should therefore not be taxable in India. The appeal was remitted to the AO for a limited purpose: to verify the assessee's period of stay from 01.04.2005 to 31.03.2012 under section 6(6) of the Income-tax Act, determine residential status, and grant any reliefs as per law. Grounds 1 and 2 were allowed for statistical purposes.
ITAT allowed the assessee's additional claim, holding that while the AO may lack jurisdiction to adjudicate an additional claim absent a revised return, the appellate authority possesses jurisdiction to admit such a claim. The Tribunal found prima facie merit in the assessee's contention that she is a not-ordinarily-resident and not a resident, and that certain foreign income should therefore not be taxable in India. The appeal was remitted to the AO for a limited purpose: to verify the assessee's period of stay from 01.04.2005 to 31.03.2012 under section 6(6) of the Income-tax Act, determine residential status, and grant any reliefs as per law. Grounds 1 and 2 were allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
