Unlawful outward remittances via Hawala using proforma invoices and electronic records proved; documents admitted, directors penalised, penalties redu...
Attachment of equivalent-value properties as proceeds of crime upheld; preventive attachment order and confirmation sustained; no independent ED reinv...
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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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