International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
Foreign exchange loss on FCCBs was treated as revenue in nature because the borrowing was for business purposes and not shown to relate to acquisition of capital assets; the disallowance of amortised forex loss was deleted. The corresponding increase in book profit under section 115JB also failed once the underlying addition was removed. Delayed employees' contribution to PF and ESI remained disallowable under section 36(1)(va) despite payment before the section 139(1) due date. In reassessment, the Tribunal held that a fresh addition for the same forex loss amounted to double taxation and deleted it.
Foreign exchange loss on FCCBs was treated as revenue in nature because the borrowing was for business purposes and not shown to relate to acquisition of capital assets; the disallowance of amortised forex loss was deleted. The corresponding increase in book profit under section 115JB also failed once the underlying addition was removed. Delayed employees' contribution to PF and ESI remained disallowable under section 36(1)(va) despite payment before the section 139(1) due date. In reassessment, the Tribunal held that a fresh addition for the same forex loss amounted to double taxation and deleted it.
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