Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
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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...
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The ITAT affirmed the appellate order deleting the impugned ad hoc disallowance made by the AO, holding that the AO had not impugned the genuineness of the expenses and had failed to appreciate their nexus with the assessee's business (including increased repair and maintenance following acquisition of two additional vessels and legitimate tour expenses). The Tribunal further sustained deletion of the proposed addition relating to alleged excess purchase value of vessels, finding the carrying value in the transferor's audited accounts duly substantiated, independent valuation unchallenged by the revenue, and recorded cost lower than original purchase price (with rupee devaluation affecting resultant cost); consequently no inflated cost or excess depreciation was established.
The ITAT affirmed the appellate order deleting the impugned ad hoc disallowance made by the AO, holding that the AO had not impugned the genuineness of the expenses and had failed to appreciate their nexus with the assessee's business (including increased repair and maintenance following acquisition of two additional vessels and legitimate tour expenses). The Tribunal further sustained deletion of the proposed addition relating to alleged excess purchase value of vessels, finding the carrying value in the transferor's audited accounts duly substantiated, independent valuation unchallenged by the revenue, and recorded cost lower than original purchase price (with rupee devaluation affecting resultant cost); consequently no inflated cost or excess depreciation was established.
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