Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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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