Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Personal hearing requirements in GST adjudication were satisfied by prior opportunities and written submissions; appellate limitation received writ-pe...
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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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