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...
Recording satisfaction during assessment proceedings is required before penalty for an alleged cash-receipt contravention of section 269SS can be validly initiated. Applying the Supreme Court principle in Jai Laxmi Rice Mills, the Tribunal treated the absence of any satisfaction or penalty initiation in the assessment order as an invalid assumption of jurisdiction. It deleted the penalty under section 271D without deciding whether section 269SS applied to cash sale consideration for immovable property.
Recording satisfaction during assessment proceedings is required before penalty for an alleged cash-receipt contravention of section 269SS can be validly initiated. Applying the Supreme Court principle in Jai Laxmi Rice Mills, the Tribunal treated the absence of any satisfaction or penalty initiation in the assessment order as an invalid assumption of jurisdiction. It deleted the penalty under section 271D without deciding whether section 269SS applied to cash sale consideration for immovable property.
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TaxTMI 
TaxTMI 
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