Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Controlled transactions cannot be used as CUP comparables for brand royalty, so that adjustment was deleted. ECB interest benchmarking accepted RBI approval as a relevant contemporaneous benchmark and deleted the adjustment. AMP expenditure was not treated as an international transaction without tangible evidence of an arrangement. Depreciation on 3G spectrum rights, DoT subscriber verification payments, prepaid distributor discount and IBM hardware lease rentals were allowed, while liabilities written back were sustained and asset restoration cost was allowed as revenue expenditure. Annual licence fee remained capital in nature with only recomputation of amortisation under the telecom licence regime, and WPC royalty charges were also allowed.
Controlled transactions cannot be used as CUP comparables for brand royalty, so that adjustment was deleted. ECB interest benchmarking accepted RBI approval as a relevant contemporaneous benchmark and deleted the adjustment. AMP expenditure was not treated as an international transaction without tangible evidence of an arrangement. Depreciation on 3G spectrum rights, DoT subscriber verification payments, prepaid distributor discount and IBM hardware lease rentals were allowed, while liabilities written back were sustained and asset restoration cost was allowed as revenue expenditure. Annual licence fee remained capital in nature with only recomputation of amortisation under the telecom licence regime, and WPC royalty charges were also allowed.
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