Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
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...
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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