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...
In a transfer pricing dispute concerning the software development services segment, the ITAT held that the Transfer Pricing Officer had not dealt with the five comparables remitted for reconsideration, and that the later DRP consideration did not cure the failure to follow the earlier appellate direction in time. The defect was treated as an irregularity requiring correction, not as a basis to annul the assessment. The Assessing Officer was therefore directed to exclude Acropetal Technologies, E-Zest Solutions, E-Infochips, ICRA Techno Analytics and Persistent Systems and recompute the arm's length price adjustment; the assessment was otherwise left undisturbed.
In a transfer pricing dispute concerning the software development services segment, the ITAT held that the Transfer Pricing Officer had not dealt with the five comparables remitted for reconsideration, and that the later DRP consideration did not cure the failure to follow the earlier appellate direction in time. The defect was treated as an irregularity requiring correction, not as a basis to annul the assessment. The Assessing Officer was therefore directed to exclude Acropetal Technologies, E-Zest Solutions, E-Infochips, ICRA Techno Analytics and Persistent Systems and recompute the arm's length price adjustment; the assessment was otherwise left undisturbed.
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