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...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Transfer pricing on loans to associated enterprises was confined to the LIBOR-based rate already accepted in earlier precedent, so no further interest adjustment was warranted. Corporate guarantee commission was retained at 0.35% on consistency with earlier years and the interest-saved approach. Deduction for rail and water systems as infrastructure facility under section 80-IA was allowed because the earlier orders had attained finality. The section 14A disallowance was restricted: interest disallowance was deleted where interest-free funds exceeded investments, and administrative expenditure was computed only on investments yielding exempt income, with corresponding book-profit relief. The gain on prepayment of sales tax deferral was treated as capital receipt, and the write-back of project creditors was not taxable under section 28(iv).
Transfer pricing on loans to associated enterprises was confined to the LIBOR-based rate already accepted in earlier precedent, so no further interest adjustment was warranted. Corporate guarantee commission was retained at 0.35% on consistency with earlier years and the interest-saved approach. Deduction for rail and water systems as infrastructure facility under section 80-IA was allowed because the earlier orders had attained finality. The section 14A disallowance was restricted: interest disallowance was deleted where interest-free funds exceeded investments, and administrative expenditure was computed only on investments yielding exempt income, with corresponding book-profit relief. The gain on prepayment of sales tax deferral was treated as capital receipt, and the write-back of project creditors was not taxable under section 28(iv).
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