Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
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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