Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
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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