Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
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The High Court upheld the assessee's aggregated benchmarking of multiple international transactions under TNMM, accepting the DRP's finding that the transactions were commercially interlinked and should be tested together. Those factual findings were not disturbed by the Tribunal. The Court also applied its earlier ruling in Cummins India Ltd., which recognises that once TNMM is accepted as the most appropriate method, one element cannot be isolated and benchmarked separately if that would distort arm's length determination. As the matter was covered by binding precedent and supported by concurrent findings, no substantial question of law arose and the Revenue's appeal was dismissed.
The High Court upheld the assessee's aggregated benchmarking of multiple international transactions under TNMM, accepting the DRP's finding that the transactions were commercially interlinked and should be tested together. Those factual findings were not disturbed by the Tribunal. The Court also applied its earlier ruling in Cummins India Ltd., which recognises that once TNMM is accepted as the most appropriate method, one element cannot be isolated and benchmarked separately if that would distort arm's length determination. As the matter was covered by binding precedent and supported by concurrent findings, no substantial question of law arose and the Revenue's appeal was dismissed.
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