Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
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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