Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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In wholesale trading of auto and CNG components, comparables engaged in retail and after-sales trade were found functionally dissimilar under Rule 10B(2)(d), so the disputed entities were excluded and the remaining comparable kept the margin within the acceptable range; the transfer pricing adjustments for AY 2016-17 and AY 2017-18 were deleted. For transporter payments, the claimed non-deduction of tax turned on verification of a deductee certificate that had not been examined by the lower authorities, so the disallowance issue was remanded for fresh factual verification and adjudication.
In wholesale trading of auto and CNG components, comparables engaged in retail and after-sales trade were found functionally dissimilar under Rule 10B(2)(d), so the disputed entities were excluded and the remaining comparable kept the margin within the acceptable range; the transfer pricing adjustments for AY 2016-17 and AY 2017-18 were deleted. For transporter payments, the claimed non-deduction of tax turned on verification of a deductee certificate that had not been examined by the lower authorities, so the disallowance issue was remanded for fresh factual verification and adjudication.
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