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...
Transfer pricing analysis turned on comparability and receivables benchmarking. EClerx Services Limited was excluded as a KPO, and Infosys BPO Limited was excluded because of its large turnover and intangibles; the Tribunal accepted the consistent approach taken in the assessee's own earlier years and declined remand for fresh benchmarking. Interest on outstanding receivables was upheld at LIBOR plus 200 basis points, following the assessee's prior year treatment and rejecting the SBI term deposit rate. The 120-day credit period was set aside as case-specific and was to follow the period adopted in the assessee's own case for AY 2013-14; section 92CE and Rule 10CB were held inapplicable by analogy.
Transfer pricing analysis turned on comparability and receivables benchmarking. EClerx Services Limited was excluded as a KPO, and Infosys BPO Limited was excluded because of its large turnover and intangibles; the Tribunal accepted the consistent approach taken in the assessee's own earlier years and declined remand for fresh benchmarking. Interest on outstanding receivables was upheld at LIBOR plus 200 basis points, following the assessee's prior year treatment and rejecting the SBI term deposit rate. The 120-day credit period was set aside as case-specific and was to follow the period adopted in the assessee's own case for AY 2013-14; section 92CE and Rule 10CB were held inapplicable by analogy.
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