Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Constitutional judicial review permits challenges to ECIRs and connected money-laundering proceedings where coercive action affects fundamental intere...
TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between two segments - The appellant challenged the actions of the Assessing Officer (AO) and Transfer Pricing Officer (TPO) in determining the ALP and rejecting their TP analysis. The Appellate Tribunal found in favor of the appellant, concluding that the TPO's actions were beyond jurisdiction and based on incorrect facts. The Tribunal upheld the appellant's use of Transfer Pricing Methodology and segmentation of accounts, directing the AO to delete the adjustments made.
TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between two segments - The appellant challenged the actions of the Assessing Officer (AO) and Transfer Pricing Officer (TPO) in determining the ALP and rejecting their TP analysis. The Appellate Tribunal found in favor of the appellant, concluding that the TPO's actions were beyond jurisdiction and based on incorrect facts. The Tribunal upheld the appellant's use of Transfer Pricing Methodology and segmentation of accounts, directing the AO to delete the adjustments made.
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