Transaction value rejection requires reliable corroboration; refundable VAT is excluded and temporary registration does not defeat new-vehicle exempti...
Appellate jurisdiction remains available where a wrist-worn gold ornament cannot conclusively be characterised as imported baggage at the preliminary ...
Written complaint requirement bars cognizance on police reports for securities offences, while unsupported breach of trust and cheating allegations fa...
Risk-based postal import clearance standardises electronic assessment, document requests, duty realisation and delivery controls at Foreign Post Offic...
Customs Cargo Service Provider appointment extends custodianship to additional terminal land, subject to cargo-control, security and licence condition...
TP Adjustment - Allowability of intergroup payment of management fees - principle of consistency - The Income Tax Appellate Tribunal (ITAT) found that the assessee failed to provide adequate evidence to substantiate the receipt and the economic benefits derived from the services allegedly provided by its AEs. - It was noted that, it is surprising that though the assessee has relied on OECD guidelines, but at the same time it is forgetting that the OECD guidelines clearly provides for Benefit Test for payment of intra group services and also the benefit test is duly recognized as several countries as mentioned by TPO/OECD in its commentary. - The Tribunal dismissed the assessee's appeals, affirming the Revenue's stance that there was insufficient evidence to justify the claimed payments towards management services.
TP Adjustment - Allowability of intergroup payment of management fees - principle of consistency - The Income Tax Appellate Tribunal (ITAT) found that the assessee failed to provide adequate evidence to substantiate the receipt and the economic benefits derived from the services allegedly provided by its AEs. - It was noted that, it is surprising that though the assessee has relied on OECD guidelines, but at the same time it is forgetting that the OECD guidelines clearly provides for Benefit Test for payment of intra group services and also the benefit test is duly recognized as several countries as mentioned by TPO/OECD in its commentary. - The Tribunal dismissed the assessee's appeals, affirming the Revenue's stance that there was insufficient evidence to justify the claimed payments towards management services.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
