Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Transactions with a wholly owned pass-through foreign LLC, whose profits were already taxed in India, were treated as self-dealing rather than separate AE dealings, so no arm's length adjustment survived and the sale adjustment was deleted. Receivables from that same entity were held intrinsically linked to the underlying sales, so the separate interest adjustment was also deleted. For specified domestic transactions, the altered TNMM filters and reduced comparables were found unjustified; the eligible unit's margin fell within the existing range, so the recomputation of profits and related deduction reduction were deleted. The standalone challenge to initiation of penalty proceedings was dismissed as premature.
Transactions with a wholly owned pass-through foreign LLC, whose profits were already taxed in India, were treated as self-dealing rather than separate AE dealings, so no arm's length adjustment survived and the sale adjustment was deleted. Receivables from that same entity were held intrinsically linked to the underlying sales, so the separate interest adjustment was also deleted. For specified domestic transactions, the altered TNMM filters and reduced comparables were found unjustified; the eligible unit's margin fell within the existing range, so the recomputation of profits and related deduction reduction were deleted. The standalone challenge to initiation of penalty proceedings was dismissed as premature.
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