Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
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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