Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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.
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