Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Transfer Pricing Adjustments on Corporate Guarantee Charges, Interest on Optionally Convertible Loans (OCL), and Reimbursement of Expenses. - The Tribunal found that these issues were adjudicated in favor of the assessee in previous years, relying on ITAT and High Court decisions. The adjustments made by the AO were not upheld, and the tribunal directed the deletion of these adjustments, affirming the assessee's approach to charging 1% corporate guarantee fees and handling of OCL and reimbursement of expenses as per the precedents.
Transfer Pricing Adjustments on Corporate Guarantee Charges, Interest on Optionally Convertible Loans (OCL), and Reimbursement of Expenses. - The Tribunal found that these issues were adjudicated in favor of the assessee in previous years, relying on ITAT and High Court decisions. The adjustments made by the AO were not upheld, and the tribunal directed the deletion of these adjustments, affirming the assessee's approach to charging 1% corporate guarantee fees and handling of OCL and reimbursement of expenses as per the precedents.
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