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 ITAT held that once TNMM benchmarking of logistics services had been accepted on a combined basis, the same cost elements could not be separately benchmarked again for royalty and GAM charges, so those additional transfer pricing adjustments were deleted. It restored the working capital adjustment to the AO/TPO for fresh consideration on the basis of the material already furnished. On CSR-related donations, the Tribunal held that disallowance under Explanation 2 to section 37(1) does not bar deduction under section 80G where the donation otherwise qualifies, and allowed the claim. TDS/TCS credit and the section 43B issue were remanded for verification and fresh decision.
The ITAT held that once TNMM benchmarking of logistics services had been accepted on a combined basis, the same cost elements could not be separately benchmarked again for royalty and GAM charges, so those additional transfer pricing adjustments were deleted. It restored the working capital adjustment to the AO/TPO for fresh consideration on the basis of the material already furnished. On CSR-related donations, the Tribunal held that disallowance under Explanation 2 to section 37(1) does not bar deduction under section 80G where the donation otherwise qualifies, and allowed the claim. TDS/TCS credit and the section 43B issue were remanded for verification and fresh decision.
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