Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
In transfer pricing under TNMM, the ITAT treated regular foreign exchange gain as operating income, held that common Delhi and Dehradun expenses had to be allocated on gross profit margins rather than turnover, and applied broad functional comparability to accept the five comparables; it also rejected exclusion of Gontermann Pieper as a persistent loss-maker because it had not suffered losses for three consecutive years. The transfer pricing adjustment was therefore restored to the TPO/AO for recomputation on those terms. On interest deduction, the ITAT applied CIT v. Rajendra Prasad Moody and allowed interest expenditure against interest income, holding that absence of dividend from the subsidiary investment did not justify disallowance. The interest disallowance was deleted.
In transfer pricing under TNMM, the ITAT treated regular foreign exchange gain as operating income, held that common Delhi and Dehradun expenses had to be allocated on gross profit margins rather than turnover, and applied broad functional comparability to accept the five comparables; it also rejected exclusion of Gontermann Pieper as a persistent loss-maker because it had not suffered losses for three consecutive years. The transfer pricing adjustment was therefore restored to the TPO/AO for recomputation on those terms. On interest deduction, the ITAT applied CIT v. Rajendra Prasad Moody and allowed interest expenditure against interest income, holding that absence of dividend from the subsidiary investment did not justify disallowance. The interest disallowance was deleted.
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