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...
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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