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...
Revision u/s 263 - Pr. CIT directed to make addition/disallowance in respect of expenditure incurred towards R&D u/s 35(2AB); Capital R&D expense allocated to Sun Pharmaceuticals Industries and re-characterization of remuneration earned from partnership firm (SPI) as royalty income - similar disallowances were already subject matter of appeals before Tribunal in earlier years in favour of assessee - revision order is not sustainable
Revision u/s 263 - Pr. CIT directed to make addition/disallowance in respect of expenditure incurred towards R&D u/s 35(2AB); Capital R&D expense allocated to Sun Pharmaceuticals Industries and re-characterization of remuneration earned from partnership firm (SPI) as royalty income - similar disallowances were already subject matter of appeals before Tribunal in earlier years in favour of assessee - revision order is not sustainable
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