Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
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Section 14A disallowance cannot be added to book profit for MAT computation under section 115JB where binding co-ordinate Bench precedent has already settled the issue. The HC followed its earlier decision in Gujarat Fluorochemicals Ltd. and the same view adopted in the taxpayer's own case, and held that no addition to book profit can be made on the basis of the section 14A disallowance. On that settled position, the Revenue's proposed questions were treated as concluded against it, and the tax appeal was dismissed for want of any substantial question of law.
Section 14A disallowance cannot be added to book profit for MAT computation under section 115JB where binding co-ordinate Bench precedent has already settled the issue. The HC followed its earlier decision in Gujarat Fluorochemicals Ltd. and the same view adopted in the taxpayer's own case, and held that no addition to book profit can be made on the basis of the section 14A disallowance. On that settled position, the Revenue's proposed questions were treated as concluded against it, and the tax appeal was dismissed for want of any substantial question of law.
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