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...
Omission of the provision defining related-party purchases as specified domestic transactions, without a saving clause, removed the statutory foundation for penalties for failure to furnish Form 3CEB. Omission is distinguished from repeal: absent a saving provision, it does not preserve a right to initiate or continue proceedings based on the omitted provision. Penalties imposed for the relevant assessment years were therefore unsustainable.
Omission of the provision defining related-party purchases as specified domestic transactions, without a saving clause, removed the statutory foundation for penalties for failure to furnish Form 3CEB. Omission is distinguished from repeal: absent a saving provision, it does not preserve a right to initiate or continue proceedings based on the omitted provision. Penalties imposed for the relevant assessment years were therefore unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
