Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Captive IT/software development service providers may exclude giant comparables where the comparables' turnover is more than ten times the assessee's, so Infosys, Wipro, LTI Mindtree and Cybage were directed to be excluded. Where the remaining companies appeared to have diversified product, agency or consultancy functions, their FAR comparability could not be finally decided on the existing record, and the matter was remanded to the AO/TPO for fresh benchmarking. Delayed trade receivables from an associated enterprise were treated as a separate international transaction; interest was sustained in principle, but only after allowing a standard credit period before computing delay. The appeal was partly allowed for statistical purposes.
Captive IT/software development service providers may exclude giant comparables where the comparables' turnover is more than ten times the assessee's, so Infosys, Wipro, LTI Mindtree and Cybage were directed to be excluded. Where the remaining companies appeared to have diversified product, agency or consultancy functions, their FAR comparability could not be finally decided on the existing record, and the matter was remanded to the AO/TPO for fresh benchmarking. Delayed trade receivables from an associated enterprise were treated as a separate international transaction; interest was sustained in principle, but only after allowing a standard credit period before computing delay. The appeal was partly allowed for statistical purposes.
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