Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Alternative statutory remedy under GST bars writ challenge where classification, notice variance, and hearing disputes require factual appellate revie...
Intra-group management and IT support charges could not be wholly rejected where associated enterprises provided services, but debit notes, allocation bases and allocation keys were necessary to verify the charges. The ad hoc restriction was improper, and the issue was remitted to the Assessing Officer/Transfer Pricing Officer for fresh examination. Interlinked trading imports and manufacturing sales required entity-level transfer pricing benchmarking because overseas associated enterprises lacked reliable comparable and complete financial data, while subsequent manufacturing operations made separate segmental RPM or TNMM analysis inappropriate. Those issues were remitted for fresh determination. The Revenue's challenge to allowance of agronomy expenditure was dismissed as covered in favour of the assessee.
Intra-group management and IT support charges could not be wholly rejected where associated enterprises provided services, but debit notes, allocation bases and allocation keys were necessary to verify the charges. The ad hoc restriction was improper, and the issue was remitted to the Assessing Officer/Transfer Pricing Officer for fresh examination. Interlinked trading imports and manufacturing sales required entity-level transfer pricing benchmarking because overseas associated enterprises lacked reliable comparable and complete financial data, while subsequent manufacturing operations made separate segmental RPM or TNMM analysis inappropriate. Those issues were remitted for fresh determination. The Revenue's challenge to allowance of agronomy expenditure was dismissed as covered in favour of the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
