Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
TP adjustment - intra-group services - Infrastructure consultancy and support charges - DR was unable to controvert the factual finding of the DRP that infrastructure and consultancy services were for development of a new plant in Sanand - these services cannot be held to be supervisory and stewardship services rendered by the AE to the assessee, as contended by the TPO and as argued by the ld.DR before us. - No TP additions - AT
TP adjustment - intra-group services - Infrastructure consultancy and support charges - DR was unable to controvert the factual finding of the DRP that infrastructure and consultancy services were for development of a new plant in Sanand - these services cannot be held to be supervisory and stewardship services rendered by the AE to the assessee, as contended by the TPO and as argued by the ld.DR before us. - No TP additions - AT
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