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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Penalty proceedings for undisclosed income found during a search require a notice under section 274 that identifies the precise charge under section 271AAB, including the applicable statutory clause and corresponding penalty rate. This specificity is necessary to provide a meaningful opportunity of hearing. A notice that merely refers generally to undisclosed income and proposed penalty under section 271AAB, without identifying the relevant conditions, is vague and invalid. Defective initiation notices invalidate consequential penalty proceedings; the penalty is deleted, leaving the substantive merits of the levy unexamined.
Penalty proceedings for undisclosed income found during a search require a notice under section 274 that identifies the precise charge under section 271AAB, including the applicable statutory clause and corresponding penalty rate. This specificity is necessary to provide a meaningful opportunity of hearing. A notice that merely refers generally to undisclosed income and proposed penalty under section 271AAB, without identifying the relevant conditions, is vague and invalid. Defective initiation notices invalidate consequential penalty proceedings; the penalty is deleted, leaving the substantive merits of the levy unexamined.
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