Independent manufacturing undertaking eligibility preserves Section 80IA/80IB deductions, while machinery kept ready for use qualifies for depreciatio...
Assessing Officer Satisfaction Requirement Bars Penalty for Cash Receipt in Immovable-Property Sale Cases Where Initiation Lacks Recorded Satisfaction...
Self-assessed import entries remain appealable, while bona fide classification disputes without misdeclaration cannot justify confiscation or penaltie...
Actual-user customs exemption conditions permit turnkey project transfers when imported windmill components are exclusively used for installation and ...
Customs offence disqualification excludes civil contraventions, preventing refusal of a private bonded warehouse licence based solely on monetary pena...
Intra-group management and IT support charges could not be wholly rejected where associated enterprises provided services, but debit notes, allocation bases and allocation keys were necessary to verify the charges. The ad hoc restriction was improper, and the issue was remitted to the Assessing Officer/Transfer Pricing Officer for fresh examination. Interlinked trading imports and manufacturing sales required entity-level transfer pricing benchmarking because overseas associated enterprises lacked reliable comparable and complete financial data, while subsequent manufacturing operations made separate segmental RPM or TNMM analysis inappropriate. Those issues were remitted for fresh determination. The Revenue's challenge to allowance of agronomy expenditure was dismissed as covered in favour of the assessee.
Intra-group management and IT support charges could not be wholly rejected where associated enterprises provided services, but debit notes, allocation bases and allocation keys were necessary to verify the charges. The ad hoc restriction was improper, and the issue was remitted to the Assessing Officer/Transfer Pricing Officer for fresh examination. Interlinked trading imports and manufacturing sales required entity-level transfer pricing benchmarking because overseas associated enterprises lacked reliable comparable and complete financial data, while subsequent manufacturing operations made separate segmental RPM or TNMM analysis inappropriate. Those issues were remitted for fresh determination. The Revenue's challenge to allowance of agronomy expenditure was dismissed as covered in favour of the assessee.
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