Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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.
Note: It is a system-generated summary and is for quick reference only.