Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
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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