Customs valuation and import permissibility conflict resolved: accepted enhancement of transaction value removes liability for confiscation and penalt...
Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
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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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