Classification of imported goods as electronic cigarette versus tobacco product reversed for lack of proof; order set aside for jurisdictional overrea...
Reversal of input tax credit in proportion to exempt supply: specificity of show-cause notice required; order set aside, fresh proceedings allowed wit...
MEIS scrip income and duty drawback were treated as operating revenue for transfer pricing because they arose directly from the assessee's export and manufacturing activities; excluding them would distort operating profit, and the absence of similar incentives in comparables was not decisive. The Tribunal also directed examination of the working capital computation on record and grant of an appropriate adjustment while determining arm's length price. On CSR-linked donations, deduction under section 80G was allowed because CSR disallowance as business expenditure does not automatically bar section 80G relief, and the statutory exclusions were not shown to apply.
MEIS scrip income and duty drawback were treated as operating revenue for transfer pricing because they arose directly from the assessee's export and manufacturing activities; excluding them would distort operating profit, and the absence of similar incentives in comparables was not decisive. The Tribunal also directed examination of the working capital computation on record and grant of an appropriate adjustment while determining arm's length price. On CSR-linked donations, deduction under section 80G was allowed because CSR disallowance as business expenditure does not automatically bar section 80G relief, and the statutory exclusions were not shown to apply.
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