Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
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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