Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
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.
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