GST payment representations require record-based, reasoned decisions while substantive entitlement remains open for determination by competent authori...
Reassessment sanction under extended limitation required approval from the competent specified authority, invalidating proceedings approved by an inco...
Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
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Intra-group services closely linked to core business operations may be benchmarked together under TNMM; where facts and the business model remain unchanged, earlier transfer-pricing treatment should be followed despite pending departmental appeals. The related transfer-pricing adjustments and connected branch-office expenditure and depreciation/depletion disallowances were accordingly deleted or allowed. Arm's-length interest on external commercial borrowings required fresh determination by the AO/TPO. Site-restoration costs incurred to discharge a contractual decommissioning obligation were allowable business expenditure despite utilisation of a provision. Refund interest depended on verification of issuance and encashment; TDS credit required verification of corresponding income; and interest for filing and advance-tax defaults could not apply where withholding covered total tax liability.
Intra-group services closely linked to core business operations may be benchmarked together under TNMM; where facts and the business model remain unchanged, earlier transfer-pricing treatment should be followed despite pending departmental appeals. The related transfer-pricing adjustments and connected branch-office expenditure and depreciation/depletion disallowances were accordingly deleted or allowed. Arm's-length interest on external commercial borrowings required fresh determination by the AO/TPO. Site-restoration costs incurred to discharge a contractual decommissioning obligation were allowable business expenditure despite utilisation of a provision. Refund interest depended on verification of issuance and encashment; TDS credit required verification of corresponding income; and interest for filing and advance-tax defaults could not apply where withholding covered total tax liability.
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