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Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held that when TNMM is applied, the net margin already accounts for such notional interest costs. Thus, no separate adjustment for notional interest on receivables was warranted, and the tribunal directed the AO to delete the upward adjustment made for overdue receivables from AEs. - Further, Ld. AO / TPO directed to examine and consider the appropriate adjustments arising out of the working capital differences in the computation of the ALP.
TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held that when TNMM is applied, the net margin already accounts for such notional interest costs. Thus, no separate adjustment for notional interest on receivables was warranted, and the tribunal directed the AO to delete the upward adjustment made for overdue receivables from AEs. - Further, Ld. AO / TPO directed to examine and consider the appropriate adjustments arising out of the working capital differences in the computation of the ALP.
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TaxTMI 
TaxTMI 
