Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
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TP addition - Specified Domestic Transaction (SDT) of Rent payment - Once it is held that the property was used by the assessee for its business purpose and the Revenue brought no contrary reliable evidence on record, the case of the TPO applying `Other method’ and determining Nil ALP on the ground that no independent party would have paid any rent for not having occupied the premises, fails. - AT
TP addition - Specified Domestic Transaction (SDT) of Rent payment - Once it is held that the property was used by the assessee for its business purpose and the Revenue brought no contrary reliable evidence on record, the case of the TPO applying `Other method’ and determining Nil ALP on the ground that no independent party would have paid any rent for not having occupied the premises, fails. - AT
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