Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
Jurisdictional facts in certificate-of-origin discrepancies can support customs show-cause proceedings, leaving factual explanations for departmental ...
TP adjustment - international transaction - expenses - incurred wholly and exclusively for the purpose of business or not - In the present case, the AO, by applying benefit test to the impugned international transaction has attempted to step into the shoes of TPO, since the benefit test could have been applied only for the purpose of determining ALP of the transaction as pointed out by the DRP also from the OECD commentary and from the various decision of the ITAT on this issue. - Additions deleted - AT
TP adjustment - international transaction - expenses - incurred wholly and exclusively for the purpose of business or not - In the present case, the AO, by applying benefit test to the impugned international transaction has attempted to step into the shoes of TPO, since the benefit test could have been applied only for the purpose of determining ALP of the transaction as pointed out by the DRP also from the OECD commentary and from the various decision of the ITAT on this issue. - Additions deleted - AT
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