Classification of imported salvaged shaft pieces as ship parts confirmed, reassessment time-barred and appeal allowed restoring original classificatio...
Scope of intermediary status for data hosting services: tribunal finds provider not intermediary, services exported and not taxable, limited remand on...
CENVAT credit availability after omission of Rule 12B in textiles confirmed; late addendum to SCN introducing new grounds held time-barred and invalid...
Export of Wheat Flour and related products subject to online allocation, eligibility criteria, non-transferable six-month authorisations and reporting...
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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