Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The ITAT ruled in favor of the assessee on multiple transfer pricing issues. The Tribunal excluded comparables Tata Elexi and Sasken Technologies, bringing the appellant's margin (9.44%) within acceptable range (11.66% +/-3%), eliminating TP adjustment. Similarly, ADTL and TCG were excluded as comparables for CRDS services. The ITAT deleted TP adjustments for intra-group services and advertisement/marketing expenses, finding the latter not to be international transactions. Additional favorable rulings included: no SS14A disallowance where no exempt income was earned; deletion of duplicative SS41(1) addition for trading liability cessation; allowance of lease rental expenses for assets on financial lease; and confirmation that SS80G deduction for CSR contributions remains available despite Explanation 2 to SS37(1).
The ITAT ruled in favor of the assessee on multiple transfer pricing issues. The Tribunal excluded comparables Tata Elexi and Sasken Technologies, bringing the appellant's margin (9.44%) within acceptable range (11.66% +/-3%), eliminating TP adjustment. Similarly, ADTL and TCG were excluded as comparables for CRDS services. The ITAT deleted TP adjustments for intra-group services and advertisement/marketing expenses, finding the latter not to be international transactions. Additional favorable rulings included: no SS14A disallowance where no exempt income was earned; deletion of duplicative SS41(1) addition for trading liability cessation; allowance of lease rental expenses for assets on financial lease; and confirmation that SS80G deduction for CSR contributions remains available despite Explanation 2 to SS37(1).
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