Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
For section 80-IA, the market value of captive power had to be benchmarked to the tariff charged by the State Electricity Board to industrial consumers, including the electricity duty component, and not to the assessee's sale price for surplus power; the assessee therefore succeeded on quantification. Deduction under section 80-IA did not require any reduction from profits eligible under section 80HHC, so the assessee also succeeded on that computation issue. For section 115JB, the entire profits eligible under section 80HHC had to be excluded from book profit, as the phased restriction in section 80HHC(1B) did not govern MAT computation. Applying the purpose test, sales tax remission linked to industrial expansion in backward areas was held to be a capital receipt and excludible from book profit.
For section 80-IA, the market value of captive power had to be benchmarked to the tariff charged by the State Electricity Board to industrial consumers, including the electricity duty component, and not to the assessee's sale price for surplus power; the assessee therefore succeeded on quantification. Deduction under section 80-IA did not require any reduction from profits eligible under section 80HHC, so the assessee also succeeded on that computation issue. For section 115JB, the entire profits eligible under section 80HHC had to be excluded from book profit, as the phased restriction in section 80HHC(1B) did not govern MAT computation. Applying the purpose test, sales tax remission linked to industrial expansion in backward areas was held to be a capital receipt and excludible from book profit.
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