Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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A second final assessment order for the same assessment year was held impermissible because a final order had already been passed pursuant to DRP directions; the later order was quashed as a duplicate assessment. Transfer pricing issues on intra-group services and royalty benchmarking were not finally decided and were remitted to the TPO for fresh adjudication and computation in line with earlier-year directions. Support service expenditure was held allowable on consistency with prior years, and the disallowance was deleted. Amortization of telecom licence fee and the related interest claim were sent back for consequential action in accordance with law. Deduction under section 80G for CSR expenditure, refund of excess dividend distribution tax at treaty rate, and road tax and VAT on leased assets were all allowed.
A second final assessment order for the same assessment year was held impermissible because a final order had already been passed pursuant to DRP directions; the later order was quashed as a duplicate assessment. Transfer pricing issues on intra-group services and royalty benchmarking were not finally decided and were remitted to the TPO for fresh adjudication and computation in line with earlier-year directions. Support service expenditure was held allowable on consistency with prior years, and the disallowance was deleted. Amortization of telecom licence fee and the related interest claim were sent back for consequential action in accordance with law. Deduction under section 80G for CSR expenditure, refund of excess dividend distribution tax at treaty rate, and road tax and VAT on leased assets were all allowed.
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