Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Transfer Pricing Adjustments - downward adjustment made by the TPO and enhanced by the CIT(A) - adoption of the Transactional Net Margin Method (TNMM) over other methods - import of capital goods from AE - The tribunal overturned the TPO's and CIT(A)'s adjustments and methodologies, reinstating the appellant's method for benchmarking international transactions as compliant with the Income Tax Rules. It emphasized that the project cost approved by regulatory commissions and financed by specialized institutions validated the appellant's expenditure on imported capital goods.
Transfer Pricing Adjustments - downward adjustment made by the TPO and enhanced by the CIT(A) - adoption of the Transactional Net Margin Method (TNMM) over other methods - import of capital goods from AE - The tribunal overturned the TPO's and CIT(A)'s adjustments and methodologies, reinstating the appellant's method for benchmarking international transactions as compliant with the Income Tax Rules. It emphasized that the project cost approved by regulatory commissions and financed by specialized institutions validated the appellant's expenditure on imported capital goods.
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