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    Related-party consultancy charges and vehicle-loan interest were accepted as genuine business expenditure, with disallowances deleted.
    Penalty limitation under section 275(1)(c) ran from AO's initiation recommendation, making the later penalty order time-barred.
    Transfer pricing comparables and receivables interest: KPO exclusion, LIBOR plus 200 basis points, and case-specific credit period applied.
    Limited scrutiny exceeded without approval; partner-funded bank credits were not taxable as firm business income
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    Separate penalty on partner and firm barred for the same contravention; admission supported false declaration penalty but amount was reduced.
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      Customs field formations are directed not to seek direct...

      FTP interpretation references must be routed through Customs channels, with direct DGFT correspondence barred and pending clearances minimised.

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      CustomsJune 4, 2026Circulars
      Customs field formations are directed not to seek direct clarification from DGFT Headquarters or Regional Authorities on interpretation of FTP provisions or policy conditions. Such issues must first be examined at Commissionerate/Zonal level, and only policy-level matters after due examination may be referred to the Board by the concerned Principal Chief Commissioner/Chief Commissioner; commodity-specific issues require prior examination and approval by the concerned National Assessment Centre. Every reference must include concise facts, the provision in question, the field interpretation, the specific point needing clarification, the number of affected cases, whether live consignments are pending, and urgency status. Pending consignments should not be kept on hold solely for interpretational issues, and provisional assessment or other facilitative mechanisms may be used where legally permissible.

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      ActsIncome Tax