Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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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