Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
Proceeds of crime: provisional attachment confirmed; equivalent value attachment and acquisition date fair market value upheld, Covid exclusion preser...
Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4821 
Join Channel 
