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 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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