Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
TP Adjustment - ALP adjustment qua receipt of management services - the assessee has already filed its detailed paper book in the nature of supportive evidence indicating receipt of management services in day to day functioning from its overseas Associated Enterprises. There is no rebuttal coming from Revenue’s side that all the said details lack genuineness which could be taken as the benchmark for arriving at nil ‘ALP’ thereof. We thus hold that the learned lower authorities action making impugned ALP adjustment is not sustainable.- AT
TP Adjustment - ALP adjustment qua receipt of management services - the assessee has already filed its detailed paper book in the nature of supportive evidence indicating receipt of management services in day to day functioning from its overseas Associated Enterprises. There is no rebuttal coming from Revenue’s side that all the said details lack genuineness which could be taken as the benchmark for arriving at nil ‘ALP’ thereof. We thus hold that the learned lower authorities action making impugned ALP adjustment is not sustainable.- AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
