Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
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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