Tax collection at source on purchases removes duplicate withholding obligation, while trade-creditor evidence requires verification before unexplained...
Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
Commodity derivatives position limits adopt revised breach penalties, broad commodity criteria, and client open-position limits based on deliverable s...
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Export quota premium is not equivalent to export-incentive receipts eligible for deduction under section 80HHC. Administrative circulars bind departmental authorities but cannot bind courts, override statutory language, or displace judicial interpretation. Equating premium from the transfer of export quota with receipts covered by the specified export-incentive provisions would create an impermissible legal fiction, particularly because such premium lacks characteristics of those receipts, including foreign-exchange realisation. Tax deductions must be construed strictly by reference to income derived and the statutory classification of eligible receipts; export quota premium therefore falls outside the claimed deduction.
Export quota premium is not equivalent to export-incentive receipts eligible for deduction under section 80HHC. Administrative circulars bind departmental authorities but cannot bind courts, override statutory language, or displace judicial interpretation. Equating premium from the transfer of export quota with receipts covered by the specified export-incentive provisions would create an impermissible legal fiction, particularly because such premium lacks characteristics of those receipts, including foreign-exchange realisation. Tax deductions must be construed strictly by reference to income derived and the statutory classification of eligible receipts; export quota premium therefore falls outside the claimed deduction.
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