Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Related party transactions filter governed the inclusion of a comparable under TNMM benchmarking: the Tribunal noted from the annual financial statements that the company's related-party service income and other related-party income exceeded 25% of total revenue, which would fail the filter if the assessee's computation is verified correct. The matter was remitted to the TPO for verification, with a direction to exclude the company from the final comparables set if the 25% threshold is breached. Penalty initiation under section 270A was held premature and dismissed.
Related party transactions filter governed the inclusion of a comparable under TNMM benchmarking: the Tribunal noted from the annual financial statements that the company's related-party service income and other related-party income exceeded 25% of total revenue, which would fail the filter if the assessee's computation is verified correct. The matter was remitted to the TPO for verification, with a direction to exclude the company from the final comparables set if the 25% threshold is breached. Penalty initiation under section 270A was held premature and dismissed.
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