Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Threshold for allottee-initiated insolvency petitions in leasehold real estate upheld; petition admitted after possession letters deemed legally ineff...
Contravention of foreign exchange rules in crossborder diamond payments; appellate tribunal reduces one appellant's penalty for delay and proportional...
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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