Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Transfer pricing adjustment on royalty payment to an AE was sustained by the DRP by adopting an arm's length royalty rate of 53% based on an earlier APA; however, since the taxpayer had executed a unilateral APA with CBDT covering the royalty transaction and had filed a modified return enhancing income accordingly, the AO was directed to give effect to the APA and reframe the order. Deduction under s. 80G for donations forming part of CSR spend was disallowed on grounds of invalid donation certificates and impermissible double benefit, but applying binding and coordinate precedents, s. 80G deduction was held allowable notwithstanding CSR claim, and the disallowance was deleted. - ITAT
Transfer pricing adjustment on royalty payment to an AE was sustained by the DRP by adopting an arm's length royalty rate of 53% based on an earlier APA; however, since the taxpayer had executed a unilateral APA with CBDT covering the royalty transaction and had filed a modified return enhancing income accordingly, the AO was directed to give effect to the APA and reframe the order. Deduction under s. 80G for donations forming part of CSR spend was disallowed on grounds of invalid donation certificates and impermissible double benefit, but applying binding and coordinate precedents, s. 80G deduction was held allowable notwithstanding CSR claim, and the disallowance was deleted. - ITAT
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