Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
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Pharmaceutical sales-promotion expenditure is disallowable only where it directly provides prohibited benefits, such as travel or hotel facilities, to medical practitioners; patient education, professional events and other non-prohibited promotional costs remain deductible. A retracted search statement without independent corroboration cannot support an over-invoicing addition. Manufacturing scrap and empty-container sales qualify for profit-linked deductions, while the industrial excise-refund incentive described is a capital receipt excluded from taxable income and book profit. Transfer-pricing analysis requires reliable functional, temporal and economic comparability; unsupported adjustments for domestic transactions, export pricing, guarantees and genuine intra-group services were rejected. The note also addresses exempt-income expenditure, foreign tax credit attribution, and independent examination of approved in-house research expenditure.
Pharmaceutical sales-promotion expenditure is disallowable only where it directly provides prohibited benefits, such as travel or hotel facilities, to medical practitioners; patient education, professional events and other non-prohibited promotional costs remain deductible. A retracted search statement without independent corroboration cannot support an over-invoicing addition. Manufacturing scrap and empty-container sales qualify for profit-linked deductions, while the industrial excise-refund incentive described is a capital receipt excluded from taxable income and book profit. Transfer-pricing analysis requires reliable functional, temporal and economic comparability; unsupported adjustments for domestic transactions, export pricing, guarantees and genuine intra-group services were rejected. The note also addresses exempt-income expenditure, foreign tax credit attribution, and independent examination of approved in-house research expenditure.
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