Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
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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