Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
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DSIR-certified capital scientific research expenditure qualified for weighted deduction at 200%, and the Tribunal directed allowance of the balance deduction where only 100% had been given on the certified amount. For uncertified capital expenditure, it held that once the expenditure was actually incurred for scientific research and that fact was undisputed, denial of weighted deduction did not bar a normal deduction under section 35(1)(iv); the Assessing Officer was directed to verify and allow it. On transfer pricing, the deletion of the adjustment was sustained because no defect was shown in the assessee's study, third-party finished-goods margins were not a proper benchmark for inter-unit transfers, and no fresh material distinguished the year from earlier years. The consequential section 80IC relief was also upheld.
DSIR-certified capital scientific research expenditure qualified for weighted deduction at 200%, and the Tribunal directed allowance of the balance deduction where only 100% had been given on the certified amount. For uncertified capital expenditure, it held that once the expenditure was actually incurred for scientific research and that fact was undisputed, denial of weighted deduction did not bar a normal deduction under section 35(1)(iv); the Assessing Officer was directed to verify and allow it. On transfer pricing, the deletion of the adjustment was sustained because no defect was shown in the assessee's study, third-party finished-goods margins were not a proper benchmark for inter-unit transfers, and no fresh material distinguished the year from earlier years. The consequential section 80IC relief was also upheld.
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