Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
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TP adjustment - The TPO has not given any reason as to why he altered the aggregate amount of Net profit. Hence the workings made by TPO is liable to rejected. We have noticed that the net profit margin worked out by the assessee in "Domestic - Personal care division" was 12.31%. The net profit margin worked out for "Exports to AEs" was 24.03%. Hence the net profit margin earned in the exports to AEs division is higher than its comparable "Domestic - Personal care division". Hence it has to be held that the international transactions of making exports to AEs are at arms length and hence no T.P adjustment is called for. - AT
TP adjustment - The TPO has not given any reason as to why he altered the aggregate amount of Net profit. Hence the workings made by TPO is liable to rejected. We have noticed that the net profit margin worked out by the assessee in "Domestic - Personal care division" was 12.31%. The net profit margin worked out for "Exports to AEs" was 24.03%. Hence the net profit margin earned in the exports to AEs division is higher than its comparable "Domestic - Personal care division". Hence it has to be held that the international transactions of making exports to AEs are at arms length and hence no T.P adjustment is called for. - AT
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