Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
ITAT followed its earlier orders in the assessee's own case and applied the same transfer pricing treatment for the year under appeal. For the ITES segment, it treated the benchmarking issue as covered by precedent and allowed the assessee's challenge to the arm's length price adjustment. For receivables from associated enterprises, it directed that delayed amounts beyond 90 days be benchmarked using 3 months' average Euribor plus 200 basis points, rather than sustaining the adjustment. For imported fixed assets, it held that a nil value could not be adopted and accepted the customs-determined value as the fair value, setting aside the transfer pricing adjustment.
ITAT followed its earlier orders in the assessee's own case and applied the same transfer pricing treatment for the year under appeal. For the ITES segment, it treated the benchmarking issue as covered by precedent and allowed the assessee's challenge to the arm's length price adjustment. For receivables from associated enterprises, it directed that delayed amounts beyond 90 days be benchmarked using 3 months' average Euribor plus 200 basis points, rather than sustaining the adjustment. For imported fixed assets, it held that a nil value could not be adopted and accepted the customs-determined value as the fair value, setting aside the transfer pricing adjustment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
