Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Transfer Pricing Adjustments - The Tribunal upheld the Ld. DRP's directions on various objections raised by the taxpayer, including the consideration of multiple-year data, peculiar economic conditions, abnormal business loss, under-utilization of capacity, and treatment of expenses. - However, the ITAT found that the Assessing Officer (AO) had not fully complied with the Ld. DRP's directions, specifically regarding working capital adjustments. It directed the AO/TPO to consider all of the Ld. DRP's directions while drafting the final assessment order. - Matter restored back.
Transfer Pricing Adjustments - The Tribunal upheld the Ld. DRP's directions on various objections raised by the taxpayer, including the consideration of multiple-year data, peculiar economic conditions, abnormal business loss, under-utilization of capacity, and treatment of expenses. - However, the ITAT found that the Assessing Officer (AO) had not fully complied with the Ld. DRP's directions, specifically regarding working capital adjustments. It directed the AO/TPO to consider all of the Ld. DRP's directions while drafting the final assessment order. - Matter restored back.
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