International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
No disallowance under section 14A was sustained where no exempt income arose; the DRP's deletion of the 14A addition was upheld. The DRP's deletion of the 40(a)(ia) TDS disallowance for transmission and uplinking payments to a foreign satellite entity was confirmed, the payer's TDS obligation negated on facts. Software and upgrade costs were held revenue in nature for broadcasting and the related disallowance deleted. The assessee's revised ESOP expense claim was allowed as deductible business expenditure. Multiple entities were excluded from TNMM comparables as functionally dissimilar; the question whether a corporate guarantee constitutes an international transaction was remitted to the AO/TPO for fresh examination.
No disallowance under section 14A was sustained where no exempt income arose; the DRP's deletion of the 14A addition was upheld. The DRP's deletion of the 40(a)(ia) TDS disallowance for transmission and uplinking payments to a foreign satellite entity was confirmed, the payer's TDS obligation negated on facts. Software and upgrade costs were held revenue in nature for broadcasting and the related disallowance deleted. The assessee's revised ESOP expense claim was allowed as deductible business expenditure. Multiple entities were excluded from TNMM comparables as functionally dissimilar; the question whether a corporate guarantee constitutes an international transaction was remitted to the AO/TPO for fresh examination.
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