Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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Transfer pricing adjustment for software development and related support services - Comparables deselected due to functional dissimilarity. TPO directed to exclude certain companies. Transfer pricing adjustment for interest on receivables - TPO's calculation of interest on entire closing balance incorrect. TPO instructed to compute interest based on delay for each invoice beyond grace period after examining agreements or market practice. Employee's PF contribution disallowed for non-compliance with statutory deposit timelines. No long-term capital gain on amount credited to capital reserve pursuant to merger, covered u/s 47(vi). Double addition in computation corrected. Finance cost disallowance deleted as no transfer pricing adjustment proposed. Advance tax credit and TDS credit from merged entity directed to be allowed based on evidence.
Transfer pricing adjustment for software development and related support services - Comparables deselected due to functional dissimilarity. TPO directed to exclude certain companies. Transfer pricing adjustment for interest on receivables - TPO's calculation of interest on entire closing balance incorrect. TPO instructed to compute interest based on delay for each invoice beyond grace period after examining agreements or market practice. Employee's PF contribution disallowed for non-compliance with statutory deposit timelines. No long-term capital gain on amount credited to capital reserve pursuant to merger, covered u/s 47(vi). Double addition in computation corrected. Finance cost disallowance deleted as no transfer pricing adjustment proposed. Advance tax credit and TDS credit from merged entity directed to be allowed based on evidence.
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