Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Weighted deduction for scientific research expenditure was allowed on regular remuneration paid to the Chief Scientific Officer, as it was incurred for day-to-day research services, but the one-time performance bonus linked to patent licensing success was excluded as not directly related to research activity. ESOP expenditure disallowance was deleted by following the Tribunal's earlier orders in the assessee's own case. Weighted deduction under section 35(2AB) was confined to expenditure verified and certified by DSIR in Form 3CL, so the balance manpower and travel claim was not extended the deduction. For the alternative claim, deduction under section 37(1) was permitted subject to verification that the same amount had not already been claimed in the profit and loss account.
Weighted deduction for scientific research expenditure was allowed on regular remuneration paid to the Chief Scientific Officer, as it was incurred for day-to-day research services, but the one-time performance bonus linked to patent licensing success was excluded as not directly related to research activity. ESOP expenditure disallowance was deleted by following the Tribunal's earlier orders in the assessee's own case. Weighted deduction under section 35(2AB) was confined to expenditure verified and certified by DSIR in Form 3CL, so the balance manpower and travel claim was not extended the deduction. For the alternative claim, deduction under section 37(1) was permitted subject to verification that the same amount had not already been claimed in the profit and loss account.
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