Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Transfer-pricing adjustments for the project business segment required fresh consideration in line with the Dispute Resolution Panel's directions, without adjudication of their merits. The ITAT restored this issue to the Transfer Pricing Officer for a lawful fresh determination after hearing the assessee. The arm's length price of intra-group services was also remanded because the Transfer Pricing Officer had accepted that price in a subsequent assessment year; the merits were not decided. The Transfer Pricing Officer must reconsider the issue after providing an opportunity of hearing. The appeals for the relevant assessment years were allowed for statistical purposes.
Transfer-pricing adjustments for the project business segment required fresh consideration in line with the Dispute Resolution Panel's directions, without adjudication of their merits. The ITAT restored this issue to the Transfer Pricing Officer for a lawful fresh determination after hearing the assessee. The arm's length price of intra-group services was also remanded because the Transfer Pricing Officer had accepted that price in a subsequent assessment year; the merits were not decided. The Transfer Pricing Officer must reconsider the issue after providing an opportunity of hearing. The appeals for the relevant assessment years were allowed for statistical purposes.
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