Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
Profit attribution to an Indian permanent establishment in cross-border M&A deals depended on the actual functions performed by each branch. The Tribunal noted that the assessee's model first split deal revenue between origination and execution, then allocated it according to each branch's role; email evidence showed active UK team involvement in execution, and the department's acceptance of substantial origination revenue allocation to overseas branches in the same deals supported that approach. The rejection of shared execution revenue was therefore unsustainable, and the addition attributed entirely to the Indian PE was deleted. The MAT credit claim was not decided on merits and was restored for factual verification and grant in accordance with law.
Profit attribution to an Indian permanent establishment in cross-border M&A deals depended on the actual functions performed by each branch. The Tribunal noted that the assessee's model first split deal revenue between origination and execution, then allocated it according to each branch's role; email evidence showed active UK team involvement in execution, and the department's acceptance of substantial origination revenue allocation to overseas branches in the same deals supported that approach. The rejection of shared execution revenue was therefore unsustainable, and the addition attributed entirely to the Indian PE was deleted. The MAT credit claim was not decided on merits and was restored for factual verification and grant in accordance with law.
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