Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Addition on account of provision made on performance guarantee/warranty - The ITAT found that the provision for performance guarantee/warranty was consistent with the company's business practices and the prior year's judicial decisions. It was considered a necessary expense directly linked to sales and customer obligations, thus not merely a tool for tax evasion. - The ITAT dismissed the Revenue's appeal.
Addition on account of provision made on performance guarantee/warranty - The ITAT found that the provision for performance guarantee/warranty was consistent with the company's business practices and the prior year's judicial decisions. It was considered a necessary expense directly linked to sales and customer obligations, thus not merely a tool for tax evasion. - The ITAT dismissed the Revenue's appeal.
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