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    Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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      Transfer pricing adjustments on intra-group management charges...

      Transfer pricing and PF/ESI timing issues led to deletion of management fee adjustment, restricted royalty, and sustained disallowance

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      Income TaxJune 11, 2026Case LawsAT
      Transfer pricing adjustments on intra-group management charges were deleted after accepting the assessee's TNMM benchmarking and rejecting a nil arm's length value. Royalty on sales was restricted by allowing 5% on both sales to associated enterprises and third parties, as the authorities could not disallow the entire payment or treat the assessee as a contract manufacturer for this purpose. For outstanding receivables, working capital adjustment had to be given first; only any remaining shortfall could be examined again for interest adjustment, so the issue was restored for fresh determination. Disallowance of employees' PF and ESI contribution deposited after the welfare law due date was sustained, as later payment within the income-tax filing timeline did not cure the default.

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      ActsIncome Tax