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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Faceless assessment permits Assessment Units to exercise Assessing Officer functions, including issuing scrutiny notices, without requiring the National Faceless Assessment Centre to issue them. ESOP discount reimbursed to a holding company constitutes employee compensation accruing over the vesting period where the liability has arisen and is reasonably estimable; later exercise, lapses or forfeitures require corresponding adjustments. A disallowance for failure to deduct tax from settlement compensation requires an identified statutory withholding obligation. Relinquishment of a right to sue does not itself establish payment for services, commission, brokerage, professional or technical services, or a non-compete arrangement; for non-resident payments, withholding depends on taxability in India.
Faceless assessment permits Assessment Units to exercise Assessing Officer functions, including issuing scrutiny notices, without requiring the National Faceless Assessment Centre to issue them. ESOP discount reimbursed to a holding company constitutes employee compensation accruing over the vesting period where the liability has arisen and is reasonably estimable; later exercise, lapses or forfeitures require corresponding adjustments. A disallowance for failure to deduct tax from settlement compensation requires an identified statutory withholding obligation. Relinquishment of a right to sue does not itself establish payment for services, commission, brokerage, professional or technical services, or a non-compete arrangement; for non-resident payments, withholding depends on taxability in India.
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