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...
The Tribunal held that comparables lacking functional similarity were to be excluded, while Keystone Integrated Marketing Services Pvt. Ltd. had to be included because the DRP had already directed its inclusion. Pass-through third-party costs in the contract R&D segment, incurred without value addition and recovered on a cost-to-cost basis, were excluded from the PLI computation and the related transfer pricing addition was deleted. Working capital adjustment was recognised as an accepted TP adjustment and directed to be verified on actuals. The DRP's direction to set off contract R&D income against royalty attribution was binding on the AO, so the adjustment was reduced accordingly. Arithmetical errors and foreign tax credit claims were remanded for verification and recomputation.
The Tribunal held that comparables lacking functional similarity were to be excluded, while Keystone Integrated Marketing Services Pvt. Ltd. had to be included because the DRP had already directed its inclusion. Pass-through third-party costs in the contract R&D segment, incurred without value addition and recovered on a cost-to-cost basis, were excluded from the PLI computation and the related transfer pricing addition was deleted. Working capital adjustment was recognised as an accepted TP adjustment and directed to be verified on actuals. The DRP's direction to set off contract R&D income against royalty attribution was binding on the AO, so the adjustment was reduced accordingly. Arithmetical errors and foreign tax credit claims were remanded for verification and recomputation.
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