Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Section 80-IA(10) can curtail a deduction only where there is a close connection, an arrangement between the parties, and that arrangement produces more than ordinary profits. The Court held that extraordinary profits alone do not prove such an arrangement, and the Tribunal had not recorded a categorical finding of one. It further found that comparing a 100% export-oriented unit with a domestic sister concern was legally unsustainable because statutory benefits and cost structures differed materially, so no proper benchmark of ordinary profit was made. The restriction of the Section 10B deduction on the sister concern's profit margin was therefore quashed and the appeal allowed.
Section 80-IA(10) can curtail a deduction only where there is a close connection, an arrangement between the parties, and that arrangement produces more than ordinary profits. The Court held that extraordinary profits alone do not prove such an arrangement, and the Tribunal had not recorded a categorical finding of one. It further found that comparing a 100% export-oriented unit with a domestic sister concern was legally unsustainable because statutory benefits and cost structures differed materially, so no proper benchmark of ordinary profit was made. The restriction of the Section 10B deduction on the sister concern's profit margin was therefore quashed and the appeal allowed.
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