Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate ...
Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
DSIR-approved in-house R&D deduction cannot be disallowed by the AO or DRP on the basis of survey statements once the prescribed authority has quantified the eligible expenditure; later survey findings do not unsettle earlier certified claims. Where procurement commission had already been benchmarked in transfer pricing proceedings, a further disallowance under the normal provisions was treated as impermissible double disallowance, absent evidence that the payment was sham. On APA-consistent transactions, the raw material purchase adjustment was restricted and the corporate guarantee adjustment was deleted or capped. Litigation provision, Chapter VI-A deduction and TDS credit issues were remitted for verification, with interest consequential and penalty premature.
DSIR-approved in-house R&D deduction cannot be disallowed by the AO or DRP on the basis of survey statements once the prescribed authority has quantified the eligible expenditure; later survey findings do not unsettle earlier certified claims. Where procurement commission had already been benchmarked in transfer pricing proceedings, a further disallowance under the normal provisions was treated as impermissible double disallowance, absent evidence that the payment was sham. On APA-consistent transactions, the raw material purchase adjustment was restricted and the corporate guarantee adjustment was deleted or capped. Litigation provision, Chapter VI-A deduction and TDS credit issues were remitted for verification, with interest consequential and penalty premature.
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