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...
Under TNMM, comparability must reflect functional, asset and risk differences, and idle capacity in a start-up ramp-up phase may require adjustment where it distorts net margins. The assessee showed its first full-fledged year of operations, a clear operational ramp-up, improved cost absorption in the next year, and a transparent methodology for the claim; the idle capacity adjustment was therefore allowed in the EPC segment. Working capital adjustment must likewise follow the tested party's actual operating cycle, including relevant operating current assets and liabilities and excluding only non-operating or financial items. Unbilled revenue and material prepayments or advances were treated as operating items, and fresh recomputation was directed subject to verification.
Under TNMM, comparability must reflect functional, asset and risk differences, and idle capacity in a start-up ramp-up phase may require adjustment where it distorts net margins. The assessee showed its first full-fledged year of operations, a clear operational ramp-up, improved cost absorption in the next year, and a transparent methodology for the claim; the idle capacity adjustment was therefore allowed in the EPC segment. Working capital adjustment must likewise follow the tested party's actual operating cycle, including relevant operating current assets and liabilities and excluding only non-operating or financial items. Unbilled revenue and material prepayments or advances were treated as operating items, and fresh recomputation was directed subject to verification.
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