Pre-trial bail granted where custodial period, documentary prosecution, and magistrate-triable offence favor release subject to surety and no witness ...
Allowability of Salary Exemptions: Form 16 entries can substantiate HRA and other salary exemptions, and home loan interest is deductible for a self-o...
Capital gains exemption: payment for plot, architect fees and bona fide commencement of construction can satisfy utilisation requirement and secure re...
Transfer pricing adjustments on corporate guarantee commission and interest on convertible loans were rejected because identical issues were previously decided in favour of the taxpayer by the ITAT; outcome: adjustments deleted. Reimbursement of expenses was held at arm's length on documentary proof and past ITAT precedent; outcome: adjustment denied. Sale of goods to an AE benchmarked using Compustat North America fell within the 3% safe harbour margin and the adjustment was dismissed. Three rejected comparables were accepted as functionally and jurisdictionally comparable; outcome: AO/TPO rejection overturned. DIANE database search for a later year failed Rule 10CA requirements; outcome: comparable search rejected. Claim for weighted R&D deduction limited to expenditure approved by the competent authority was upheld; outcome: deduction restricted to DSIR-approved quantum.
Transfer pricing adjustments on corporate guarantee commission and interest on convertible loans were rejected because identical issues were previously decided in favour of the taxpayer by the ITAT; outcome: adjustments deleted. Reimbursement of expenses was held at arm's length on documentary proof and past ITAT precedent; outcome: adjustment denied. Sale of goods to an AE benchmarked using Compustat North America fell within the 3% safe harbour margin and the adjustment was dismissed. Three rejected comparables were accepted as functionally and jurisdictionally comparable; outcome: AO/TPO rejection overturned. DIANE database search for a later year failed Rule 10CA requirements; outcome: comparable search rejected. Claim for weighted R&D deduction limited to expenditure approved by the competent authority was upheld; outcome: deduction restricted to DSIR-approved quantum.
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