Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Delayed recovery of associated enterprise receivables was held not to justify a working capital transfer pricing adjustment where the branch was debt-free, had no borrowings or interest claim, and its working capital needs were funded by head office, so no opportunity cost or borrowed-funds assumption was shown. The Tribunal therefore found no basis to interfere with deletion of the adjustment. Interest under section 234D was treated as consequential, and that ground was accepted on the assessee's concession.
Delayed recovery of associated enterprise receivables was held not to justify a working capital transfer pricing adjustment where the branch was debt-free, had no borrowings or interest claim, and its working capital needs were funded by head office, so no opportunity cost or borrowed-funds assumption was shown. The Tribunal therefore found no basis to interfere with deletion of the adjustment. Interest under section 234D was treated as consequential, and that ground was accepted on the assessee's concession.
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