Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
Transfer pricing adjustment under s.92 required correct segmentation where the tax authority had aggregated marketing support/indenting and spare parts trading (AMC) as a single segment. The Tribunal held benchmarking must be performed separately for the two segments as presented by the taxpayer; the TPO must re-examine comparables and verify whether the taxpayer's results fall within the tolerance range under the proviso to s.92C(2), and the ALP determination was remanded. On non-compete fee, in light of the latest binding precedent, it was held to be revenue in nature; the AO was directed to treat it accordingly and to recompute consequential depreciation impact already claimed with the taxpayer's assistance - ITAT
Transfer pricing adjustment under s.92 required correct segmentation where the tax authority had aggregated marketing support/indenting and spare parts trading (AMC) as a single segment. The Tribunal held benchmarking must be performed separately for the two segments as presented by the taxpayer; the TPO must re-examine comparables and verify whether the taxpayer's results fall within the tolerance range under the proviso to s.92C(2), and the ALP determination was remanded. On non-compete fee, in light of the latest binding precedent, it was held to be revenue in nature; the AO was directed to treat it accordingly and to recompute consequential depreciation impact already claimed with the taxpayer's assistance - ITAT
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