Transfer pricing adjustment on exports to foreign AEs was deleted because the tested-party selection and benchmarking method had already been accepted in the assessee's own earlier year. Section 41(1) additions for old creditors failed since remission or cessation was not proved and the balances were either paid or written back and offered to tax. Weighted deduction under section 35(2AB) was allowed despite absence of Form 3CL, and contract research income was to be reduced by expenditure, not gross receipts. Disallowance of common interest to tax holiday units was rejected where own funds were sufficient. Section 14A relief was upheld subject to the exempt-income ceiling, while excise duty exemption and specified export incentives were treated as capital receipts; some factual issues were remanded.
Transfer pricing adjustment on exports to foreign AEs was deleted because the tested-party selection and benchmarking method had already been accepted in the assessee's own earlier year. Section 41(1) additions for old creditors failed since remission or cessation was not proved and the balances were either paid or written back and offered to tax. Weighted deduction under section 35(2AB) was allowed despite absence of Form 3CL, and contract research income was to be reduced by expenditure, not gross receipts. Disallowance of common interest to tax holiday units was rejected where own funds were sufficient. Section 14A relief was upheld subject to the exempt-income ceiling, while excise duty exemption and specified export incentives were treated as capital receipts; some factual issues were remanded.
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