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 controversy turned on the correct characterization of transactions between an LLP and its associated enterprise, the proper appreciation of their FAR profiles, and the resulting arm's length pricing analysis. The Tribunal noted that the revenue authorities had relied on assumptions about the entities' activities and risk allocation, while the assessee's claim of cost-to-cost reimbursement had not been tested against complete contemporaneous material, including financials, employee profile, contractual terms and risk assumption. It held that the basis for applying the Profit Split Method was insufficiently reasoned and required fresh examination. The assessment and DRP-backed adjustment were set aside and the matter was restored to the AO/TPO for de novo adjudication and a speaking order.
Transfer pricing controversy turned on the correct characterization of transactions between an LLP and its associated enterprise, the proper appreciation of their FAR profiles, and the resulting arm's length pricing analysis. The Tribunal noted that the revenue authorities had relied on assumptions about the entities' activities and risk allocation, while the assessee's claim of cost-to-cost reimbursement had not been tested against complete contemporaneous material, including financials, employee profile, contractual terms and risk assumption. It held that the basis for applying the Profit Split Method was insufficiently reasoned and required fresh examination. The assessment and DRP-backed adjustment were set aside and the matter was restored to the AO/TPO for de novo adjudication and a speaking order.
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