Section 153C requires person-specific search authority and year-specific incriminating material for unabated assessments while preventing unsupported ...
ITAT treated notional interest on overdue receivables from...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as business expenditure.
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ITAT treated notional interest on overdue receivables from associated enterprises as unwarranted where the taxpayer was debt-free, resulting in deletion of the transfer-pricing adjustment. It also treated employee stock option plan costs as allowable business expenditure rather than capital expenditure and deleted the corresponding disallowance. The appeal was partly allowed on those grounds.
ITAT treated notional interest on overdue receivables from associated enterprises as unwarranted where the taxpayer was debt-free, resulting in deletion of the transfer-pricing adjustment. It also treated employee stock option plan costs as allowable business expenditure rather than capital expenditure and deleted the corresponding disallowance. The appeal was partly allowed on those grounds.
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