Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Appointment of Registrars as adjudicating officers under Companies Act reallocates territorial jurisdiction and sets appeal route to Regional Director...
For exempt-income disallowance under Rule 8D, only investments that actually yielded exempt income were to be considered, and the matter was remitted for recomputation. Notional interest on business advances was deleted because there was no actual accrual or receipt and the advances were not shown to be lending transactions. In transfer pricing, foreign currency loans repayable in US dollars were to be benchmarked by reference to LIBOR, not the domestic lending rate, while TNMM for AE sales was upheld and excluded comparables were sustained. A separate adjustment on outstanding receivables was rejected where working-capital effects were already reflected. The section 14A amount was also not added to book profit under MAT.
For exempt-income disallowance under Rule 8D, only investments that actually yielded exempt income were to be considered, and the matter was remitted for recomputation. Notional interest on business advances was deleted because there was no actual accrual or receipt and the advances were not shown to be lending transactions. In transfer pricing, foreign currency loans repayable in US dollars were to be benchmarked by reference to LIBOR, not the domestic lending rate, while TNMM for AE sales was upheld and excluded comparables were sustained. A separate adjustment on outstanding receivables was rejected where working-capital effects were already reflected. The section 14A amount was also not added to book profit under MAT.
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