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...
The ITAT upheld the TP adjustment for software development services to AE. L&T Infotech was considered comparable, rejecting appellant's argument. Persistent Systems Ltd's exclusion request was denied as it was part of the final comparables list. Imputing interest on receivables should use prevailing Indian rates or LIBOR with markup. The case law supports market-determined rates for benchmarking. Disallowance of employee PF contribution was upheld u/s 36(1)(va) u/s 2(24)(x) based on Checkmate Services case, stating belated remittance is not deductible even if paid before the return filing due date.
The ITAT upheld the TP adjustment for software development services to AE. L&T Infotech was considered comparable, rejecting appellant's argument. Persistent Systems Ltd's exclusion request was denied as it was part of the final comparables list. Imputing interest on receivables should use prevailing Indian rates or LIBOR with markup. The case law supports market-determined rates for benchmarking. Disallowance of employee PF contribution was upheld u/s 36(1)(va) u/s 2(24)(x) based on Checkmate Services case, stating belated remittance is not deductible even if paid before the return filing due date.
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