International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
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Disallowance under section 14A/Rule 8D: Rule 8D disallowance must be computed only with reference to investments that actually yielded exempt income, and AO is directed to recompute disallowance at 1% of the monthly average of those exempt-income-yielding investments - disallowance restricted accordingly. Disallowance added to book profit u/s 115JB: Clause (f) of Explanation 1 to s.115JB is to be computed without applying s.14A/Rule 8D, therefore the 14A addition to book profit is deleted. Interest on borrowings for interest-free advances: where own non-interest funds cover advances, no disallowance of borrowed interest - addition deleted. Vastu payments/depreciation: recurring large payments not for business purpose - addition upheld (disallowed). Government subsidy: treated as income under amended law - appeal dismissed. Royalty: deductible only on actual payment under s.43B - confirmed. Leave-encashment provision for 115JB: remitted to AO to decide under Explanation (1). Interest on belated TDS: allowed in computing book profit. 80IA transfer-pricing adjustment: deleted. SBN deposits u/s 68: remitted to AO for verification; matter allowed for statistical purposes. - ITAT
Disallowance under section 14A/Rule 8D: Rule 8D disallowance must be computed only with reference to investments that actually yielded exempt income, and AO is directed to recompute disallowance at 1% of the monthly average of those exempt-income-yielding investments - disallowance restricted accordingly. Disallowance added to book profit u/s 115JB: Clause (f) of Explanation 1 to s.115JB is to be computed without applying s.14A/Rule 8D, therefore the 14A addition to book profit is deleted. Interest on borrowings for interest-free advances: where own non-interest funds cover advances, no disallowance of borrowed interest - addition deleted. Vastu payments/depreciation: recurring large payments not for business purpose - addition upheld (disallowed). Government subsidy: treated as income under amended law - appeal dismissed. Royalty: deductible only on actual payment under s.43B - confirmed. Leave-encashment provision for 115JB: remitted to AO to decide under Explanation (1). Interest on belated TDS: allowed in computing book profit. 80IA transfer-pricing adjustment: deleted. SBN deposits u/s 68: remitted to AO for verification; matter allowed for statistical purposes. - ITAT
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