Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
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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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