Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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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