Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
TNMM was accepted for intra-group management fees and technology and trademark licence fees because the same transactions had been treated as interlinked in earlier and subsequent years, with no change in functions, assets or risks shown and evidence of services and business benefit on record; the CUP-based nil valuation was therefore unsustainable and the transfer pricing adjustments were deleted. SAP implementation cost was also treated as a reasonable, scientific allocation for IT support services because the services were used daily, billed by actual user headcount, and the need and rendition tests were satisfied; the nil ALP adjustment was deleted. The disallowance of employees' contribution to Provident Fund and ESIC was sustained under the Supreme Court ruling in Checkmate Service Private Limited.
TNMM was accepted for intra-group management fees and technology and trademark licence fees because the same transactions had been treated as interlinked in earlier and subsequent years, with no change in functions, assets or risks shown and evidence of services and business benefit on record; the CUP-based nil valuation was therefore unsustainable and the transfer pricing adjustments were deleted. SAP implementation cost was also treated as a reasonable, scientific allocation for IT support services because the services were used daily, billed by actual user headcount, and the need and rendition tests were satisfied; the nil ALP adjustment was deleted. The disallowance of employees' contribution to Provident Fund and ESIC was sustained under the Supreme Court ruling in Checkmate Service Private Limited.
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