Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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TP Adjustment - bilateral Advance Pricing Agreement (APA) between India and the USA - modified return of income - The ITAT found merit in the assessee's argument regarding the APA between India and the USA, agreeing that the methodology used for the transactions had been agreed upon. It directed the Assessing Officer to consider the modified return of income in light of the APA and decide the issue afresh after affording reasonable opportunity to the assessee. The court allowed this ground for statistical purposes.
TP Adjustment - bilateral Advance Pricing Agreement (APA) between India and the USA - modified return of income - The ITAT found merit in the assessee's argument regarding the APA between India and the USA, agreeing that the methodology used for the transactions had been agreed upon. It directed the Assessing Officer to consider the modified return of income in light of the APA and decide the issue afresh after affording reasonable opportunity to the assessee. The court allowed this ground for statistical purposes.
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