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 court held that where the subject matter relates to different financial years, a composite intimation and single show-cause notice are impermissible: separate intimations and, after considering statutory replies, separate DRC-01 show-cause proceedings are required - consequence: the impugned intimation and show-cause notice are quashed and set aside. The court permitted respondents liberty to reinitiate proceedings lawfully and to take appropriate action on or before 15.1.2026, and directed that any adjudication thereafter be completed within a reasonable time but not later than 31.3.2026. - HC
The court held that where the subject matter relates to different financial years, a composite intimation and single show-cause notice are impermissible: separate intimations and, after considering statutory replies, separate DRC-01 show-cause proceedings are required - consequence: the impugned intimation and show-cause notice are quashed and set aside. The court permitted respondents liberty to reinitiate proceedings lawfully and to take appropriate action on or before 15.1.2026, and directed that any adjudication thereafter be completed within a reasonable time but not later than 31.3.2026. - HC
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