Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
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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