Penalty for estimation of income and disallowances for tax non-deduction clarified: estimation-based penalties not sustainable; additions without conc...
Managerial remuneration disallowance under s.40A(2)(b) challenged over alleged tax-avoidance; appellate decision restored deletion of addition for dir...
Classification of imported goods as electronic cigarette versus tobacco product reversed for lack of proof; order set aside for jurisdictional overrea...
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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