Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Transfer pricing comparables were revisited because the stated related party transaction filter exclusions were not supported by the record. The exclusion of I Services India Private Limited required verification of available financial details and fresh computation of the related party transaction percentage before reconsidering inclusion. The exclusion of Cheers Interactive India Private Limited also required recomputation, after excluding payments to key managerial personnel in India from the related party transaction filter, before deciding comparability. On the corporate tax issue, the alleged disallowance of interest on TDS appeared to have been added twice in processing the return, so the Assessing Officer was directed to verify duplication and delete any double addition if established.
Transfer pricing comparables were revisited because the stated related party transaction filter exclusions were not supported by the record. The exclusion of I Services India Private Limited required verification of available financial details and fresh computation of the related party transaction percentage before reconsidering inclusion. The exclusion of Cheers Interactive India Private Limited also required recomputation, after excluding payments to key managerial personnel in India from the related party transaction filter, before deciding comparability. On the corporate tax issue, the alleged disallowance of interest on TDS appeared to have been added twice in processing the return, so the Assessing Officer was directed to verify duplication and delete any double addition if established.
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