Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Management support services supported by agreements, invoices, allocation records, presentations, e-mails and time sheets were treated as genuine business services, not mere stewardship or shareholder activities, so the arm's length price could not be fixed at nil without applying a recognised transfer pricing method. In the manufacturing segment, TNMM analysis showed the tested party's operating margin remained higher than the corrected comparable margin, so no transfer pricing adjustment could survive. The appellate deletion of both adjustments was sustained.
Management support services supported by agreements, invoices, allocation records, presentations, e-mails and time sheets were treated as genuine business services, not mere stewardship or shareholder activities, so the arm's length price could not be fixed at nil without applying a recognised transfer pricing method. In the manufacturing segment, TNMM analysis showed the tested party's operating margin remained higher than the corrected comparable margin, so no transfer pricing adjustment could survive. The appellate deletion of both adjustments was sustained.
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