Reassessment under s.148A held valid; s.69 additions totaling Rs.7,00,000 deleted after acceptable contemporaneous explanations for property investmen...
Adjudication set aside; Rule 9 valuation based on internet engineer report quashed for Rule 3(4) non-compliance; Section 138B cross-examination requir...
ITAT remanded the transfer-pricing issues to the file of the AO/TPO for fresh benchmarking of international transactions, holding that key contentions raised by the assessee regarding pricing and comparability were raised for the first time on appeal and require reconsideration; grounds 2-8 were partly allowed for statistical purposes. The Tribunal directed the AO/TPO to permit interest disallowance under the proviso to s.36(1) to be treated as revenue expenditure in favour of the assessee. The Tribunal also held that contested advertisement expenditure is revenue in nature and allowed the corresponding ground of appeal.
ITAT remanded the transfer-pricing issues to the file of the AO/TPO for fresh benchmarking of international transactions, holding that key contentions raised by the assessee regarding pricing and comparability were raised for the first time on appeal and require reconsideration; grounds 2-8 were partly allowed for statistical purposes. The Tribunal directed the AO/TPO to permit interest disallowance under the proviso to s.36(1) to be treated as revenue expenditure in favour of the assessee. The Tribunal also held that contested advertisement expenditure is revenue in nature and allowed the corresponding ground of appeal.
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