Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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HC held that expenditure towards MRF Pace Foundation constitutes business promotion and is not a charitable donation. The revenue's power is limited to examining the genuineness of expenditure. Regarding reassessment, the court ruled differently for various assessment years: for AY 2002-03, reassessment was barred by limitation; for AY 2004-05, revenue's jurisdiction was upheld; for AY 2003-04 and 2004-05, amendments to Section 80HHC were not applicable. The court affirmed the assessee's entitlement to deductions under Sections 80IA and 80IB for rubber manufacturing units, emphasizing a seamless continuation of tax benefits across assessment years.
HC held that expenditure towards MRF Pace Foundation constitutes business promotion and is not a charitable donation. The revenue's power is limited to examining the genuineness of expenditure. Regarding reassessment, the court ruled differently for various assessment years: for AY 2002-03, reassessment was barred by limitation; for AY 2004-05, revenue's jurisdiction was upheld; for AY 2003-04 and 2004-05, amendments to Section 80HHC were not applicable. The court affirmed the assessee's entitlement to deductions under Sections 80IA and 80IB for rubber manufacturing units, emphasizing a seamless continuation of tax benefits across assessment years.
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