Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Transfer pricing adjustments challenged: internal Comparable Uncontrolled Price benchmarking for interest on loans to associated enterprises upheld and ad hoc 100 basis point forex risk addition rejected, resulting in deletion of the upward interest adjustment. Notional interest on overdue receivables treated as part of the principal international sale transaction and deleted. Depreciation claim on goodwill arising from amalgamation sustained for lack of commercial substance challenge. Allocation of common expenses to incentivised units accepted where supported by separate books. Weighted deduction under research provisions not confined to the amount in approval form. Disallowances under interest allocation and Rule 8D deleted; commission to non resident agents not taxable in India absent business connection.
Transfer pricing adjustments challenged: internal Comparable Uncontrolled Price benchmarking for interest on loans to associated enterprises upheld and ad hoc 100 basis point forex risk addition rejected, resulting in deletion of the upward interest adjustment. Notional interest on overdue receivables treated as part of the principal international sale transaction and deleted. Depreciation claim on goodwill arising from amalgamation sustained for lack of commercial substance challenge. Allocation of common expenses to incentivised units accepted where supported by separate books. Weighted deduction under research provisions not confined to the amount in approval form. Disallowances under interest allocation and Rule 8D deleted; commission to non resident agents not taxable in India absent business connection.
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