Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
Proceeds of crime: provisional attachment confirmed; equivalent value attachment and acquisition date fair market value upheld, Covid exclusion preser...
Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Pure cost-to-cost reimbursements for IT infrastructure and software support, seconded employee salaries, and travel costs were treated as non-income items, not fees for technical, managerial, or consultancy services, so no withholding obligation arose and the related disallowances were deleted. On receivables, the text states that where the advance pricing agreement did not fix a specific date for applying prevailing LIBOR, the assessee's use of publicly available six-month USD LIBOR was accepted and the transfer pricing adjustment for delayed realisation of invoices was set aside.
Pure cost-to-cost reimbursements for IT infrastructure and software support, seconded employee salaries, and travel costs were treated as non-income items, not fees for technical, managerial, or consultancy services, so no withholding obligation arose and the related disallowances were deleted. On receivables, the text states that where the advance pricing agreement did not fix a specific date for applying prevailing LIBOR, the assessee's use of publicly available six-month USD LIBOR was accepted and the transfer pricing adjustment for delayed realisation of invoices was set aside.
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