Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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ITAT allowed the appeal in part and directed the AO to delete the disallowance under s.36(1)(va) where one-day delay in PF deposit was caused by bank website failure, holding the delay not attributable to the assessee-appellant. The Tribunal deleted the addition of Health and Education Cess in computing book profit under s.115JB, finding no legislative mandate equating that cess with income-tax for s.115JB purposes. ITAT directed inclusion of the Rs.1.50/unit reliability charge in transfer price for s.80IA, held the appellant's solid waste management system eligible for s.80IA deduction (applying PSM and FAR 79.73%), granted depreciation on leasehold rights under s.32(1)(ii) including opening WDV, and directed allowance of s.80IA/80IC deductions and indexed cost benefit in book-profit computation.
ITAT allowed the appeal in part and directed the AO to delete the disallowance under s.36(1)(va) where one-day delay in PF deposit was caused by bank website failure, holding the delay not attributable to the assessee-appellant. The Tribunal deleted the addition of Health and Education Cess in computing book profit under s.115JB, finding no legislative mandate equating that cess with income-tax for s.115JB purposes. ITAT directed inclusion of the Rs.1.50/unit reliability charge in transfer price for s.80IA, held the appellant's solid waste management system eligible for s.80IA deduction (applying PSM and FAR 79.73%), granted depreciation on leasehold rights under s.32(1)(ii) including opening WDV, and directed allowance of s.80IA/80IC deductions and indexed cost benefit in book-profit computation.
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