Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Appointment of Registrars as adjudicating officers under Companies Act reallocates territorial jurisdiction and sets appeal route to Regional Director...
Composite supply of drilling services and site specific chemicals characterised as composite supply; prior advance rulings set aside, tax rate left op...
Transfer pricing adjustment on intra-group IGS/ITSS was deleted because the services were not mere stewardship/shareholder activities and the evidence showed the payments were incurred for business benefit and were at arm's length; consequently, the TPO's NIL ALP determination was unsustainable. Transfer pricing adjustment on marketing support services was also deleted as TNMM, consistently accepted in earlier years, remained the most appropriate method, and CUP was wrongly applied due to lack of stringent functional/product/market comparability. Disallowance of employees' PF contribution for a one-day delay was directed to be rectified as the DRP had already required corrective action, and the AO was ordered to pass a rectification after hearing. CSR-related donation was held eligible for section 80G deduction since section 37 bar does not extend to Chapter VI-A except specified funds; deduction was allowed. - ITAT
Transfer pricing adjustment on intra-group IGS/ITSS was deleted because the services were not mere stewardship/shareholder activities and the evidence showed the payments were incurred for business benefit and were at arm's length; consequently, the TPO's NIL ALP determination was unsustainable. Transfer pricing adjustment on marketing support services was also deleted as TNMM, consistently accepted in earlier years, remained the most appropriate method, and CUP was wrongly applied due to lack of stringent functional/product/market comparability. Disallowance of employees' PF contribution for a one-day delay was directed to be rectified as the DRP had already required corrective action, and the AO was ordered to pass a rectification after hearing. CSR-related donation was held eligible for section 80G deduction since section 37 bar does not extend to Chapter VI-A except specified funds; deduction was allowed. - ITAT
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