Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
Rectification in transfer pricing proceedings was required where the assessee claimed that an international transaction had been wrongly allocated between segments and sought corrected segmental financials; the matter was remitted for verification and fresh decision after hearing. Comparable margins, as well as working capital and risk adjustments, were also restored for examination by the AO/TPO, with no merits adjudicated and all surviving transfer pricing grounds sent back for fresh adjudication.
Rectification in transfer pricing proceedings was required where the assessee claimed that an international transaction had been wrongly allocated between segments and sought corrected segmental financials; the matter was remitted for verification and fresh decision after hearing. Comparable margins, as well as working capital and risk adjustments, were also restored for examination by the AO/TPO, with no merits adjudicated and all surviving transfer pricing grounds sent back for fresh adjudication.
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