Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
Transfer pricing adjustments on intra-group technical support...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examination
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Transfer pricing adjustments on intra-group technical support services were rejected where services were demonstrated, CUP benchmarking was not displaced, and the payments were not shareholder activities. Royalty paid under the technical collaboration arrangement remained revenue expenditure under the consistency principle, while straight-line operating lease rent based on AS-19 and depreciation on a river-bank embankment previously included in the block of assets were allowed. Employees' contribution disallowance was remanded to determine the applicable provision in light of Checkmate India and prevent double addition. A warranty provision was also remanded because its scientific basis, warranty period and utilisation were not adequately supported by reliable evidence. The appeal was partly allowed for statistical purposes.
Transfer pricing adjustments on intra-group technical support services were rejected where services were demonstrated, CUP benchmarking was not displaced, and the payments were not shareholder activities. Royalty paid under the technical collaboration arrangement remained revenue expenditure under the consistency principle, while straight-line operating lease rent based on AS-19 and depreciation on a river-bank embankment previously included in the block of assets were allowed. Employees' contribution disallowance was remanded to determine the applicable provision in light of Checkmate India and prevent double addition. A warranty provision was also remanded because its scientific basis, warranty period and utilisation were not adequately supported by reliable evidence. The appeal was partly allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4788
Join Channel
TaxTMI 
