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...
Imported network interface cards/communication modules were classifiable as "parts" under CTI 8517 70 90, not as machines under CTI 8517 62 90, because an article is not a "part" only if it can perform an independent individual function on a standalone basis; here the goods could not communicate or achieve the intended transmission function unless slotted/assembled and configured with other components, akin to parts that are functionally inseparable from the host apparatus, so the reclassification demand failed. Invocation of the extended limitation period was unsustainable because mere self-assessment and an alleged revenue-motivated classification did not establish willful misstatement or suppression on the facts, so the demand was time-barred; the impugned order was set aside and the appeal allowed. - CESTAT
Imported network interface cards/communication modules were classifiable as "parts" under CTI 8517 70 90, not as machines under CTI 8517 62 90, because an article is not a "part" only if it can perform an independent individual function on a standalone basis; here the goods could not communicate or achieve the intended transmission function unless slotted/assembled and configured with other components, akin to parts that are functionally inseparable from the host apparatus, so the reclassification demand failed. Invocation of the extended limitation period was unsustainable because mere self-assessment and an alleged revenue-motivated classification did not establish willful misstatement or suppression on the facts, so the demand was time-barred; the impugned order was set aside and the appeal allowed. - CESTAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
