Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
ITAT followed its earlier orders in the assessee's own case and applied the same transfer pricing treatment for the year under appeal. For the ITES segment, it treated the benchmarking issue as covered by precedent and allowed the assessee's challenge to the arm's length price adjustment. For receivables from associated enterprises, it directed that delayed amounts beyond 90 days be benchmarked using 3 months' average Euribor plus 200 basis points, rather than sustaining the adjustment. For imported fixed assets, it held that a nil value could not be adopted and accepted the customs-determined value as the fair value, setting aside the transfer pricing adjustment.
ITAT followed its earlier orders in the assessee's own case and applied the same transfer pricing treatment for the year under appeal. For the ITES segment, it treated the benchmarking issue as covered by precedent and allowed the assessee's challenge to the arm's length price adjustment. For receivables from associated enterprises, it directed that delayed amounts beyond 90 days be benchmarked using 3 months' average Euribor plus 200 basis points, rather than sustaining the adjustment. For imported fixed assets, it held that a nil value could not be adopted and accepted the customs-determined value as the fair value, setting aside the transfer pricing adjustment.
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