Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Appointment of Registrars as adjudicating officers under Companies Act reallocates territorial jurisdiction and sets appeal route to Regional Director...
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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