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...
Cross country pipeline classification and ITC entitlement: pipelines outside factory treated as immovable, ITC disallowed under Section 17 restriction...
Disallowance of interest was contested on the ground that short-term borrowings were used for long-term investment and only a limited period of capitalization was warranted. Relying on the audit report evidencing diversion of short-term loans to capital projects already put to use, and noting that capital work-in-progress was undisputed, the appellate authority correctly sustained capitalization of interest only for four months and deleted the balance disallowance; the revenue's challenge was rejected. On transfer pricing for sugar exports, CUP-based benchmarking using FOB-converted prices with an average of NYBOT and Kingsman rates, along with the statutory tolerance range under section 92C(2), was upheld; no interference was warranted. On ferrous exports, contracts were accepted as CUP and adjustment restricted; the revenue's ground failed. - ITAT
Disallowance of interest was contested on the ground that short-term borrowings were used for long-term investment and only a limited period of capitalization was warranted. Relying on the audit report evidencing diversion of short-term loans to capital projects already put to use, and noting that capital work-in-progress was undisputed, the appellate authority correctly sustained capitalization of interest only for four months and deleted the balance disallowance; the revenue's challenge was rejected. On transfer pricing for sugar exports, CUP-based benchmarking using FOB-converted prices with an average of NYBOT and Kingsman rates, along with the statutory tolerance range under section 92C(2), was upheld; no interference was warranted. On ferrous exports, contracts were accepted as CUP and adjustment restricted; the revenue's ground failed. - ITAT
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