Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Transfer pricing issue: preference share investment was treated as a disguised loan and recharacterised for TP purposes on substance-over-form grounds; DRP/TPO conclusion was affirmed and interest benchmarked accordingly. Disallowance under exempt-income allocation: the assessee's suo motu ad hoc apportionment of employee and overhead costs was rejected as unsupported. Interest disallowance against investments was denied where interest free funds exceeded investments; administrative disallowance to be recomputed per relevant precedent. An additional ground on cost attribution for captive steam was refused; AO correctly attributed full plant cost to electricity, eliminating the 80 IA deduction. Interest deduction for acquisition of control denied for lack of nexus; alternative claim against dividend income rejected. Matters on post retirement medical provision and in house R&D expenditure restored to AO for factual examination; AO directed to consider rectification for foreign tax credit.
Transfer pricing issue: preference share investment was treated as a disguised loan and recharacterised for TP purposes on substance-over-form grounds; DRP/TPO conclusion was affirmed and interest benchmarked accordingly. Disallowance under exempt-income allocation: the assessee's suo motu ad hoc apportionment of employee and overhead costs was rejected as unsupported. Interest disallowance against investments was denied where interest free funds exceeded investments; administrative disallowance to be recomputed per relevant precedent. An additional ground on cost attribution for captive steam was refused; AO correctly attributed full plant cost to electricity, eliminating the 80 IA deduction. Interest deduction for acquisition of control denied for lack of nexus; alternative claim against dividend income rejected. Matters on post retirement medical provision and in house R&D expenditure restored to AO for factual examination; AO directed to consider rectification for foreign tax credit.
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