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...
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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