Interest on Wrongful Input Tax Credit is mandatory where excess transitional credit was retained and later reversed, and related objections were rejec...
Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
Disallowance of AMP payments as non-genuine: tribunal accepted appellate authority's finding that vendors were regular, turnover corroborated payments and AO raised no material to rebut genuineness - disallowance deleted. Disallowance of salaries paid via credit-notes: tribunal held on facts that deployment of staff at retailers for product promotion is a legitimate marketing model, credit-notes and payments were substantiated and profits remained healthy - disallowance deleted. Apportionment of AMP between assessee and contract manufacturers claiming 80IC benefits: tribunal found brand, formula and marketing exclusively controlled by assessee and prior assessments accepted ALP - no reallocation warranted. Section 14A/Rule 8D: tribunal restricted disallowance to investments that yielded exempt income, following binding precedents - addition limited accordingly. - ITAT
Disallowance of AMP payments as non-genuine: tribunal accepted appellate authority's finding that vendors were regular, turnover corroborated payments and AO raised no material to rebut genuineness - disallowance deleted. Disallowance of salaries paid via credit-notes: tribunal held on facts that deployment of staff at retailers for product promotion is a legitimate marketing model, credit-notes and payments were substantiated and profits remained healthy - disallowance deleted. Apportionment of AMP between assessee and contract manufacturers claiming 80IC benefits: tribunal found brand, formula and marketing exclusively controlled by assessee and prior assessments accepted ALP - no reallocation warranted. Section 14A/Rule 8D: tribunal restricted disallowance to investments that yielded exempt income, following binding precedents - addition limited accordingly. - ITAT
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