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...
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The High Court held that the Bright Line Test could not be adopted for transfer pricing because it is not provided under the Income-tax Act, 1961 or the Rules and is alien to the statutory scheme; the proposed question was rejected. It also declined to entertain the royalty adjustment questions, noting that the need for any transfer pricing adjustment, the computation method, and the arm's length price had already been decided in the assessee's own cases, with no contrary Supreme Court ruling shown. The exclusion of Febulka Advertising Pvt. Ltd. as a comparable was treated as a factual finding based on its different business and incomplete public data, beyond interference under section 260A. The appeal was dismissed.
The High Court held that the Bright Line Test could not be adopted for transfer pricing because it is not provided under the Income-tax Act, 1961 or the Rules and is alien to the statutory scheme; the proposed question was rejected. It also declined to entertain the royalty adjustment questions, noting that the need for any transfer pricing adjustment, the computation method, and the arm's length price had already been decided in the assessee's own cases, with no contrary Supreme Court ruling shown. The exclusion of Febulka Advertising Pvt. Ltd. as a comparable was treated as a factual finding based on its different business and incomplete public data, beyond interference under section 260A. The appeal was dismissed.
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