International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Revision under s.263 was examined on multiple deductions. Corporate club membership fees were held to be business expenditure under s.37(1), supported by binding precedent, hence the AO's allowance was not "erroneous"; revision was set aside on this issue. ESOP expense was treated as incurred in the course of business with nexus to employee compensation and consistent judicial acceptance; the AO's view was plausible, so revision failed on this issue. CSR outgo, once disallowed under s.37(1), could still qualify for s.80G if conditions were met; mere difference of opinion could not sustain s.263, so revision was quashed. Stock exchange "penalties" were compensatory charges for procedural lapses, not hit by Expln.1 to s.37(1); revision was rejected. Interest under s.36(1)(iii) lacked nexus with CWIP; proviso was inapplicable and revision was invalid; assessee's appeal allowed. - ITAT
Revision under s.263 was examined on multiple deductions. Corporate club membership fees were held to be business expenditure under s.37(1), supported by binding precedent, hence the AO's allowance was not "erroneous"; revision was set aside on this issue. ESOP expense was treated as incurred in the course of business with nexus to employee compensation and consistent judicial acceptance; the AO's view was plausible, so revision failed on this issue. CSR outgo, once disallowed under s.37(1), could still qualify for s.80G if conditions were met; mere difference of opinion could not sustain s.263, so revision was quashed. Stock exchange "penalties" were compensatory charges for procedural lapses, not hit by Expln.1 to s.37(1); revision was rejected. Interest under s.36(1)(iii) lacked nexus with CWIP; proviso was inapplicable and revision was invalid; assessee's appeal allowed. - ITAT
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