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...
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Pecuniary jurisdiction limits under the applicable CBDT instruction required reassessment of a non-corporate assessee in a mofussil area exceeding the prescribed limit to be handled by an Assistant or Deputy Commissioner, rather than an Income-tax Officer. As the reassessment notice was issued by an officer lacking that jurisdiction and the defect was unrebutted, the notice was inherently invalid. The consequential assessment was quashed as void ab initio, rendering the remaining grounds academic.
Pecuniary jurisdiction limits under the applicable CBDT instruction required reassessment of a non-corporate assessee in a mofussil area exceeding the prescribed limit to be handled by an Assistant or Deputy Commissioner, rather than an Income-tax Officer. As the reassessment notice was issued by an officer lacking that jurisdiction and the defect was unrebutted, the notice was inherently invalid. The consequential assessment was quashed as void ab initio, rendering the remaining grounds academic.
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