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    Assessee allowed to apply funds under s.11(1)(a) for foreign institute fees and forex losses for Indian education
    Revision under s.263 set aside; capital reduction loss, loan waiver and interest write-off allowed under section 2(14)
    Remittal of transfer pricing issues; AO/TPO to verify tested party, determine ALP for goods/APIs; Rule 10CB interest
    AO's use of s.153C invalid for lack of individualized satisfaction; failure to issue s.144C(1) draft order vitiates final assessments
    Assessment disallowances deleted; s.14A r.w.r.8D and s.80IAB deductions allowed; brokerage and settlement fees treated as revenue expense
    Sections 153A and 153C additions deleted where seized documents matched declared Rs.10.43 crore sale, no undisclosed income found
    Expatriate salary expenses deductible to Indian branch; interest from head office non-taxable; Section 115JB (MAT) held inapplicable
    s.276C(2) requires willful tax evasion; mere delay due to bona fide financial difficulty not sufficient for prosecution
    Petitioner directed to pursue alternate remedy under s.246A; recovery stayed and appeal filings condoned kept in abeyance
    Assessment limited to Rs.2,84,060 under s.69; reopening barred after Income Disclosure Scheme declaration, ss.147/144/144B quashed
    Felling and sale of eucalyptus and wattle trees held agricultural income under s.2(1A); AO disallowance quashed
    Condonation under s.119(2)(b) validates assessee's s.115BAA option; AO to verify Form 10-IC and recompute 22% tax
    Penalty under s.271F deleted as USD 1,200,000 foreign loan proved, non-resident status and reasonable cause under s.273B
    Assessee AOP's returned donations and discounts treated as ordinary taxable business expenses; disallowances deleted on mutuality grounds
    Section 263 revision set aside; AO assessment restored as not erroneous or prejudicial to revenue
    Article 8 DTAA covers all shipping freight and linked inland haulage; shipping income not taxable in India under Section 44B
    Appeal allowed for statistical purposes; dismissal under s.249(2) set aside as time-barred, remanded for merits
    Reopening under s.148 upheld where unexplained credits under s.68 and intentional omission of records justified additions
    Appeal allows marketing payments as deductible business expenses under Sec.37; director pay retained; R&D deductible from certificate date under Sec.3...
    Transfer pricing appeal partially allowed: TNMM median margin upheld, MSA-backed continuous services negate Nil ALP; verify PF/ESI double disallowance
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Acts Income Tax