Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Arm's length price of intra-group managerial, testing, validation and engineering services could not be fixed at nil where the assessee had benchmarked the international transactions on an aggregated TNMM basis, shown margins above comparables, and produced documentation on service receipt, business need and benefit; the Tribunal therefore deleted the transfer pricing adjustments. On outstanding receivables, no separate notional interest adjustment survived once the underlying transactions were benchmarked under TNMM with working capital adjustment, so that addition was also deleted. The claim based on payment-basis deduction for leave encashment and bonus was rejected because the disallowance had arisen only in the intimation and not in the draft or final assessment order under appeal.
Arm's length price of intra-group managerial, testing, validation and engineering services could not be fixed at nil where the assessee had benchmarked the international transactions on an aggregated TNMM basis, shown margins above comparables, and produced documentation on service receipt, business need and benefit; the Tribunal therefore deleted the transfer pricing adjustments. On outstanding receivables, no separate notional interest adjustment survived once the underlying transactions were benchmarked under TNMM with working capital adjustment, so that addition was also deleted. The claim based on payment-basis deduction for leave encashment and bonus was rejected because the disallowance had arisen only in the intimation and not in the draft or final assessment order under appeal.
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