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...
Customs valuation and classification require comparable evidence and assessment of imported goods in their actual condition, invalidating related pena...
ITAT upheld deletion of transfer-pricing adjustment on corporate guarantee, holding that no fresh guarantee was issued and no additional cost or economic outflow arose, so no arm's length commission could be imputed. It also sustained deletion of interest disallowance on borrowed funds, finding commercial expediency and no direct nexus with diversion. Weighted deduction under section 35(2AB) was largely allowed on the pre-amendment position, product registration expenditure was treated as revenue, and section 14A/MAT additions were restricted to actual exempt-income related expenditure. Foreign exchange derivative loss was accepted as business loss, while disallowance for freebies to doctors and delayed employees' contribution was upheld. The bonus deduction claim under section 43B was remanded for verification.
ITAT upheld deletion of transfer-pricing adjustment on corporate guarantee, holding that no fresh guarantee was issued and no additional cost or economic outflow arose, so no arm's length commission could be imputed. It also sustained deletion of interest disallowance on borrowed funds, finding commercial expediency and no direct nexus with diversion. Weighted deduction under section 35(2AB) was largely allowed on the pre-amendment position, product registration expenditure was treated as revenue, and section 14A/MAT additions were restricted to actual exempt-income related expenditure. Foreign exchange derivative loss was accepted as business loss, while disallowance for freebies to doctors and delayed employees' contribution was upheld. The bonus deduction claim under section 43B was remanded for verification.
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