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...
ITAT Mumbai adjudicated multiple taxation issues, primarily focusing on disallowance under Section 14A, transfer pricing adjustments, and book profit calculations. The tribunal largely ruled in favor of the assessee, deleting disallowances related to notional interest expenditure and performance guarantees. Specifically, the ITAT held that no disallowance under Section 14A can be made without recorded officer satisfaction, and no transfer pricing adjustment is required for performance guarantees where no actual financial obligation exists. For book profit computation under Section 115JB, the tribunal restricted additional disallowances, following precedent that Rule 8D adjustments cannot be added while computing book profit. Both revenue's and assessee's appeals were ultimately allowed for statistical purposes, with key adjustments deleted or remanded.
ITAT Mumbai adjudicated multiple taxation issues, primarily focusing on disallowance under Section 14A, transfer pricing adjustments, and book profit calculations. The tribunal largely ruled in favor of the assessee, deleting disallowances related to notional interest expenditure and performance guarantees. Specifically, the ITAT held that no disallowance under Section 14A can be made without recorded officer satisfaction, and no transfer pricing adjustment is required for performance guarantees where no actual financial obligation exists. For book profit computation under Section 115JB, the tribunal restricted additional disallowances, following precedent that Rule 8D adjustments cannot be added while computing book profit. Both revenue's and assessee's appeals were ultimately allowed for statistical purposes, with key adjustments deleted or remanded.
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