Retrospective cancellation of charitable registration under section 12AB(4) was unsustainable; related-party benefit allegations did not prove nongenu...
Merger control notice and disclosure rules: Supreme Court limits penalties, rejects reopening of approved combination, and sets aside adverse findings...
Royalty-related transfer pricing adjustment was deleted because audited records showed that research and development costs had already been recovered from associated enterprises with a markup of about 10%, making any further adjustment for an alleged unpaid intangible component unwarranted. The adjustment on management support services was also deleted because the assessee had benchmarked interlinked international transactions on an aggregated TNMM basis, and isolating one service for a different method was impermissible. The services, allocation mechanism, and supporting evidence were substantiated, so ALP at nil could not stand.
Royalty-related transfer pricing adjustment was deleted because audited records showed that research and development costs had already been recovered from associated enterprises with a markup of about 10%, making any further adjustment for an alleged unpaid intangible component unwarranted. The adjustment on management support services was also deleted because the assessee had benchmarked interlinked international transactions on an aggregated TNMM basis, and isolating one service for a different method was impermissible. The services, allocation mechanism, and supporting evidence were substantiated, so ALP at nil could not stand.
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