Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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