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...
Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all relevant particulars, including the arm's length price (ALP) of interest in the transfer pricing study report. - The Appellate Tribunal observed that the loan transaction between the assessee and its AE was indeed a matter of international transaction. However, considering the explanations provided by the assessee, including the nature of the transaction as an equity investment, the Tribunal ruled that the imposition of penalties was not warranted.
Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all relevant particulars, including the arm's length price (ALP) of interest in the transfer pricing study report. - The Appellate Tribunal observed that the loan transaction between the assessee and its AE was indeed a matter of international transaction. However, considering the explanations provided by the assessee, including the nature of the transaction as an equity investment, the Tribunal ruled that the imposition of penalties was not warranted.
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