Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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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