Condonation of Delay denied: communication lapses and corporate restructuring found insufficient; prolonged inaction and lack of bona fides led to ref...
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Transfer pricing adjustment on imports from associated enterprise was deleted because the taxpayer had substantiated comparable uncontrolled prices with supporting bills, and the same CUP/RPM approach had been accepted in the immediately preceding remand proceedings and in subsequent years; applying the consistency principle, the deletion of the adjustment for manufacturing, trading, and services segments was upheld, dismissing the Revenue's ground. Ad hoc disallowance of foreign travel was restricted since the taxpayer had not been specifically called upon to furnish details; a 10% disallowance of total foreign travel expenditure was sustained, partly allowing the Revenue's ground. Disallowance under section 40(a)(i) for alleged non-deduction under section 195 on allocated expenses paid abroad was deleted as the AO failed to identify year-wise accrual and the items were otherwise justified; the Revenue's challenge failed - ITAT
Transfer pricing adjustment on imports from associated enterprise was deleted because the taxpayer had substantiated comparable uncontrolled prices with supporting bills, and the same CUP/RPM approach had been accepted in the immediately preceding remand proceedings and in subsequent years; applying the consistency principle, the deletion of the adjustment for manufacturing, trading, and services segments was upheld, dismissing the Revenue's ground. Ad hoc disallowance of foreign travel was restricted since the taxpayer had not been specifically called upon to furnish details; a 10% disallowance of total foreign travel expenditure was sustained, partly allowing the Revenue's ground. Disallowance under section 40(a)(i) for alleged non-deduction under section 195 on allocated expenses paid abroad was deleted as the AO failed to identify year-wise accrual and the items were otherwise justified; the Revenue's challenge failed - ITAT
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