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...
Recorded tyre sales already included in audited books and taxable profits could not also be treated as a separate source of income through an alleged cash return. Retaining the sales in the profit and loss account while assessing the alleged returned cash separately would result in double taxation, particularly where sale records, vouchers and stock records disclosed no identified defect; the cash-return addition was deleted. Commission allegedly retained for facilitating accommodation entries through those sales remained added because the assessee conceded it, without merits adjudication.
Recorded tyre sales already included in audited books and taxable profits could not also be treated as a separate source of income through an alleged cash return. Retaining the sales in the profit and loss account while assessing the alleged returned cash separately would result in double taxation, particularly where sale records, vouchers and stock records disclosed no identified defect; the cash-return addition was deleted. Commission allegedly retained for facilitating accommodation entries through those sales remained added because the assessee conceded it, without merits adjudication.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
