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 partially allowed the assessee's appeal across multiple tax-related issues. The Tribunal directed the AO to: (1) determine arm's length pricing for royalty payments using TNMM method, (2) recompute interest on outstanding receivables using LIBOR+200 points, (3) delete gratuity expenses disallowance under section 43B, (4) verify and grant foreign tax credit with proper documentation, (5) review Dividend Distribution Tax credit and related interest calculations, and (6) substantiate or remove ad-hoc interest levy. The decision emphasizes procedural fairness, statutory compliance, and principled tax assessment, allowing most grounds of appeal for statistical purposes with specific directional instructions to the Assessing Officer.
ITAT partially allowed the assessee's appeal across multiple tax-related issues. The Tribunal directed the AO to: (1) determine arm's length pricing for royalty payments using TNMM method, (2) recompute interest on outstanding receivables using LIBOR+200 points, (3) delete gratuity expenses disallowance under section 43B, (4) verify and grant foreign tax credit with proper documentation, (5) review Dividend Distribution Tax credit and related interest calculations, and (6) substantiate or remove ad-hoc interest levy. The decision emphasizes procedural fairness, statutory compliance, and principled tax assessment, allowing most grounds of appeal for statistical purposes with specific directional instructions to the Assessing Officer.
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