Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
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Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
The ITAT dismissed challenges to any question of law regarding disallowance of royalty paid by the assessee to its AE, holding that the TPO's role is confined to determining arm's-length price and not to interrogate commercial efficacy; factual findings that manufacturers were subcontractors and no royalty was paid abroad remain uncontroverted. Transfer-pricing adjustments to AMP expenses (both substantive and protective) are deleted, the Tribunal's application of both the intensity approach and the BLT being held not in accordance with law. The assessee's method of valuing opening and closing stock at cost or net realisable value is upheld. The claim for a lower rate of DDT is rejected and decided against the assessee.
The ITAT dismissed challenges to any question of law regarding disallowance of royalty paid by the assessee to its AE, holding that the TPO's role is confined to determining arm's-length price and not to interrogate commercial efficacy; factual findings that manufacturers were subcontractors and no royalty was paid abroad remain uncontroverted. Transfer-pricing adjustments to AMP expenses (both substantive and protective) are deleted, the Tribunal's application of both the intensity approach and the BLT being held not in accordance with law. The assessee's method of valuing opening and closing stock at cost or net realisable value is upheld. The claim for a lower rate of DDT is rejected and decided against the assessee.
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