Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
Incentive payments to employees under an executive gain-sharing plan were held to be additional remuneration in the nature of bonus/incentive, not severance compensation; since the liability crystallised during the year and the unpaid portion was discharged before the return-filing due date, the expenditure was allowable under s. 43B(c) read with the first proviso, and the disallowance was deleted. For transfer pricing of an ITES provider, a high-end KPO company and a professional/accounting advisory company were excluded due to functional dissimilarity and inadequate data, while several routine ITES/BPO comparables were included based on functional similarity, availability of segmental/quarterly data, and consistency with prior years. For s. 10AA, reallocation of common costs without corresponding revenue adjustment under a cost-plus model was rejected; since books were not rejected u/s 145, deletion of the resulting addition was upheld - ITAT
Incentive payments to employees under an executive gain-sharing plan were held to be additional remuneration in the nature of bonus/incentive, not severance compensation; since the liability crystallised during the year and the unpaid portion was discharged before the return-filing due date, the expenditure was allowable under s. 43B(c) read with the first proviso, and the disallowance was deleted. For transfer pricing of an ITES provider, a high-end KPO company and a professional/accounting advisory company were excluded due to functional dissimilarity and inadequate data, while several routine ITES/BPO comparables were included based on functional similarity, availability of segmental/quarterly data, and consistency with prior years. For s. 10AA, reallocation of common costs without corresponding revenue adjustment under a cost-plus model was rejected; since books were not rejected u/s 145, deletion of the resulting addition was upheld - ITAT
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