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...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Nil ALP cannot be sustained on a benefit test where a franchise payment is for a composite bundle of rights and services; the transfer pricing addition and the alternate Section 37(1) disallowance were deleted because the arrangement was for business purposes and the taxpayer's earlier-year benchmarking had been accepted. On intra-group services, the nil ALP adjustment was also rejected because agreements, invoices and allocation records showed services were received and the tax authorities could not deny deduction by questioning commercial necessity. For purchase of goods, two comparables were excluded, while inclusion of other comparables, margin computation and working capital adjustment were restored for fresh adjudication.
Nil ALP cannot be sustained on a benefit test where a franchise payment is for a composite bundle of rights and services; the transfer pricing addition and the alternate Section 37(1) disallowance were deleted because the arrangement was for business purposes and the taxpayer's earlier-year benchmarking had been accepted. On intra-group services, the nil ALP adjustment was also rejected because agreements, invoices and allocation records showed services were received and the tax authorities could not deny deduction by questioning commercial necessity. For purchase of goods, two comparables were excluded, while inclusion of other comparables, margin computation and working capital adjustment were restored for fresh adjudication.
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