Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
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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