Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Employee conflict disclosures and investment restrictions expand with new recusal duties, post-employment limits, and compliance reporting requirement...
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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