Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
TP Adjustment - selection of MAM - Tribunal held that resale price method adopted by the assessee in determining its ALP of international transactions with AE, is not applicable, while remanding the matter back to the TPO for fresh determination - Transfer Pricing Officer is directed to redo the entire process of determination of ALP of international transactions with AE, without being influenced by any observation made by the Tribunal and render an independent finding with regard to the issues involved herein - HC
TP Adjustment - selection of MAM - Tribunal held that resale price method adopted by the assessee in determining its ALP of international transactions with AE, is not applicable, while remanding the matter back to the TPO for fresh determination - Transfer Pricing Officer is directed to redo the entire process of determination of ALP of international transactions with AE, without being influenced by any observation made by the Tribunal and render an independent finding with regard to the issues involved herein - HC
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