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 comparability adjustments were examined on foreign exchange fluctuation, customs duty, price penetration, liability write-back, and capacity utilisation. Consistent treatment of foreign exchange movement as non-operating in earlier and later years led to remand for fresh consideration. Customs duty and price penetration adjustment claims were also remitted because the factual basis and supporting details were not adequately examined. Liability write-back was treated as operating income where the underlying trade payables related to operating expenses, while other breakup items required verification. For capacity utilisation, the Tribunal rejected a depreciation-to-sales adjustment method as not reasonably accurate, but directed recomputation of ALP using cash PLI for the assessee and comparables.
Transfer pricing comparability adjustments were examined on foreign exchange fluctuation, customs duty, price penetration, liability write-back, and capacity utilisation. Consistent treatment of foreign exchange movement as non-operating in earlier and later years led to remand for fresh consideration. Customs duty and price penetration adjustment claims were also remitted because the factual basis and supporting details were not adequately examined. Liability write-back was treated as operating income where the underlying trade payables related to operating expenses, while other breakup items required verification. For capacity utilisation, the Tribunal rejected a depreciation-to-sales adjustment method as not reasonably accurate, but directed recomputation of ALP using cash PLI for the assessee and comparables.
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