Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
Transfer pricing adjustment on intra-group services was deleted because the Tribunal followed binding decisions in the assessee's own earlier years, affirmed by the Gujarat High Court, holding that actual receipt of services and business nexus had been demonstrated. It accepted that the TPO could not fix arm's length price at nil merely on perceived lack of benefit, duplication, or shareholder characterisation, and that an ALP determination requires application of a prescribed benchmarking method with comparable uncontrolled analysis. The grounds challenging the validity of assessment were dismissed as not pressed, and the appeal was partly allowed.
Transfer pricing adjustment on intra-group services was deleted because the Tribunal followed binding decisions in the assessee's own earlier years, affirmed by the Gujarat High Court, holding that actual receipt of services and business nexus had been demonstrated. It accepted that the TPO could not fix arm's length price at nil merely on perceived lack of benefit, duplication, or shareholder characterisation, and that an ALP determination requires application of a prescribed benchmarking method with comparable uncontrolled analysis. The grounds challenging the validity of assessment were dismissed as not pressed, and the appeal was partly allowed.
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