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...
Rule 138B permits physical verification of a conveyance by a proper officer authorised by the Commissioner; an authorisation-based challenge fails where the officer holds that authority and no jurisdictional defect is established. Writ jurisdiction despite an alternative statutory appeal remains confined to exceptional circumstances, including infringement of fundamental rights, breach of natural justice, lack of jurisdiction, or challenge to statutory validity. Where a fresh show-cause notice, personal hearing, consideration of the reply, and relevant detention, verification and registration-cancellation material are provided, complaints concerning relied-upon documents require appellate examination. The writ challenge to confiscation was dismissed, leaving the statutory appeal available.
Rule 138B permits physical verification of a conveyance by a proper officer authorised by the Commissioner; an authorisation-based challenge fails where the officer holds that authority and no jurisdictional defect is established. Writ jurisdiction despite an alternative statutory appeal remains confined to exceptional circumstances, including infringement of fundamental rights, breach of natural justice, lack of jurisdiction, or challenge to statutory validity. Where a fresh show-cause notice, personal hearing, consideration of the reply, and relevant detention, verification and registration-cancellation material are provided, complaints concerning relied-upon documents require appellate examination. The writ challenge to confiscation was dismissed, leaving the statutory appeal available.
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