Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
DSIR certification supported deduction under section 35(2AB) because the Tribunal applied judicial consistency and held that the Assessing Officer could not disregard the certified R&D expenditure without following the statutory procedure. It also sustained deletion of manufacturing-expense and R&D additions made on post-survey extrapolation, finding no abnormality in the expense ratio and no rebuttal of the factual findings. As those disallowances failed on merits, the reassessment based on the same grounds was held invalid. For the later year, interest disallowance linked to a loan treated as unexplained cash credit was deleted once that underlying addition no longer survived, while other claims were sent back for factual verification.
DSIR certification supported deduction under section 35(2AB) because the Tribunal applied judicial consistency and held that the Assessing Officer could not disregard the certified R&D expenditure without following the statutory procedure. It also sustained deletion of manufacturing-expense and R&D additions made on post-survey extrapolation, finding no abnormality in the expense ratio and no rebuttal of the factual findings. As those disallowances failed on merits, the reassessment based on the same grounds was held invalid. For the later year, interest disallowance linked to a loan treated as unexplained cash credit was deleted once that underlying addition no longer survived, while other claims were sent back for factual verification.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
