Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Interest income on fixed deposits was held not taxable because the assessee, being wholly owned and constituted to perform governmental functions as an instrumentality of the State, qualifies as "State" under Article 12 read with Article 289 of the Constitution; consequently, such interest was treated as not derived from a taxable trade or business and the corresponding addition was deleted. Grant-in-aid received from the State Government was also held non-taxable since it was received by the assessee in its capacity as an arm of the State for executing public projects, and the related addition was directed to be deleted. - ITAT
Interest income on fixed deposits was held not taxable because the assessee, being wholly owned and constituted to perform governmental functions as an instrumentality of the State, qualifies as "State" under Article 12 read with Article 289 of the Constitution; consequently, such interest was treated as not derived from a taxable trade or business and the corresponding addition was deleted. Grant-in-aid received from the State Government was also held non-taxable since it was received by the assessee in its capacity as an arm of the State for executing public projects, and the related addition was directed to be deleted. - ITAT
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