Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
TP Adjustment - MAM - Considering brokerage rate of all Non-AEs for the comparability purposes - Arm's Length Price (ALP) of broking commissions - The Tribunal directed the Transfer Pricing Officer (TPO) to consider both overseas and domestic clients while applying the Comparable Uncontrolled Price (CUP) method. Adjustment of 40% was allowed on marketing and research costs. - AT
TP Adjustment - MAM - Considering brokerage rate of all Non-AEs for the comparability purposes - Arm's Length Price (ALP) of broking commissions - The Tribunal directed the Transfer Pricing Officer (TPO) to consider both overseas and domestic clients while applying the Comparable Uncontrolled Price (CUP) method. Adjustment of 40% was allowed on marketing and research costs. - AT
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