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...
Statutory personal hearing under GST requires a real and effective opportunity where a taxable person requests a hearing before an adverse adjudication. Failure to provide a post-reply hearing vitiates the original adjudication and requires fresh consideration. A reasoned order must address the taxpayer's explanation, relevant facts, evidentiary basis, and grounds for inferring an additional taxable supply; a bare rejection of the reply is insufficient. Non-cancellation of a duplicate e-way bill is a material but non-conclusive circumstance, requiring cumulative assessment with primary evidence and surrounding facts. Following amendment, pre-show-cause intimation is enabling, so its non-issuance does not independently require remand.
Statutory personal hearing under GST requires a real and effective opportunity where a taxable person requests a hearing before an adverse adjudication. Failure to provide a post-reply hearing vitiates the original adjudication and requires fresh consideration. A reasoned order must address the taxpayer's explanation, relevant facts, evidentiary basis, and grounds for inferring an additional taxable supply; a bare rejection of the reply is insufficient. Non-cancellation of a duplicate e-way bill is a material but non-conclusive circumstance, requiring cumulative assessment with primary evidence and surrounding facts. Following amendment, pre-show-cause intimation is enabling, so its non-issuance does not independently require remand.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
