Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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ITAT rejected the Revenue's Rule 46A objection because the EPCG licence documents and computation were already part of the record before the Assessing Officer, and no fresh evidence had been admitted by the first appellate authority. It further upheld deletion of the addition relating to the Government grant, holding that the amount had been credited in the books under Ind-AS-compliant accounting, was tax neutral for income-tax purposes, and had already been included in the returned total income. A further addition would therefore result in double addition. The Revenue's appeal was dismissed.
ITAT rejected the Revenue's Rule 46A objection because the EPCG licence documents and computation were already part of the record before the Assessing Officer, and no fresh evidence had been admitted by the first appellate authority. It further upheld deletion of the addition relating to the Government grant, holding that the amount had been credited in the books under Ind-AS-compliant accounting, was tax neutral for income-tax purposes, and had already been included in the returned total income. A further addition would therefore result in double addition. The Revenue's appeal was dismissed.
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