Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
Transfer pricing issue concerned royalty paid to an associated enterprise where the adjustment was negated in favour of the taxpayer because the earlier appellate decision in the taxpayer's own case on the same issue precluded fresh adjustment; the assessing officer had relied on a prior TPO finding but the appellate precedent established nil ALP, resulting in relief. Separately, claim for deduction under the industrial/infrastructure undertaking provision for participation in a micro irrigation project was allowed after the taxpayer produced execution copies, invoices, payments and certificates; a typographical error in the agreement party name was held not to defeat entitlement and the revenue failed to rebut the evidence.
Transfer pricing issue concerned royalty paid to an associated enterprise where the adjustment was negated in favour of the taxpayer because the earlier appellate decision in the taxpayer's own case on the same issue precluded fresh adjustment; the assessing officer had relied on a prior TPO finding but the appellate precedent established nil ALP, resulting in relief. Separately, claim for deduction under the industrial/infrastructure undertaking provision for participation in a micro irrigation project was allowed after the taxpayer produced execution copies, invoices, payments and certificates; a typographical error in the agreement party name was held not to defeat entitlement and the revenue failed to rebut the evidence.
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