Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
Jurisdictional facts in certificate-of-origin discrepancies can support customs show-cause proceedings, leaving factual explanations for departmental ...
Under the combined transaction approach to TNMM, separate benchmarking of royalty and Global Accounts Manager charges is impermissible where those costs are already included in the operating costs of the logistics segment being benchmarked. The transfer pricing adjustments for those items were therefore deleted, consistent with the principle that individual cost elements embedded in an accepted combined segment analysis should not be separately benchmarked without a corresponding cost-base adjustment. Claims concerning TDS credit and errors in computing interest and fees were treated as computational matters requiring verification and were remitted to the Assessing Officer for fresh consideration after providing an opportunity of hearing. The appeal was consequently partly allowed.
Under the combined transaction approach to TNMM, separate benchmarking of royalty and Global Accounts Manager charges is impermissible where those costs are already included in the operating costs of the logistics segment being benchmarked. The transfer pricing adjustments for those items were therefore deleted, consistent with the principle that individual cost elements embedded in an accepted combined segment analysis should not be separately benchmarked without a corresponding cost-base adjustment. Claims concerning TDS credit and errors in computing interest and fees were treated as computational matters requiring verification and were remitted to the Assessing Officer for fresh consideration after providing an opportunity of hearing. The appeal was consequently partly allowed.
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