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...
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Reassessment of a section 80JJAA deduction cannot rest solely on a change of opinion where the deduction was specifically examined and accepted during the original scrutiny assessment. Employee, cost and supporting details had been furnished for the original assessment, while the reopening notice and the order under section 148A(d) identified no fresh tangible material indicating income escapement. The reassessment proceedings were therefore invalidated as a review of material already considered, and the section 148 notice and section 148A(d) order were quashed.
Reassessment of a section 80JJAA deduction cannot rest solely on a change of opinion where the deduction was specifically examined and accepted during the original scrutiny assessment. Employee, cost and supporting details had been furnished for the original assessment, while the reopening notice and the order under section 148A(d) identified no fresh tangible material indicating income escapement. The reassessment proceedings were therefore invalidated as a review of material already considered, and the section 148 notice and section 148A(d) order were quashed.
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