Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Validity of order of ITAT allowing Applications filed u/s 254(2) - Rectification versus Review of order - TP Adjustment - The High court observed that the ITAT had rendered incompatible and inconsistent findings in its original order. - The court noted a contradiction between paragraphs 12 and 21 of the original order. - It was deemed necessary for the ITAT to recall its previous order and correct the error to avoid leaving the TPO and Assessing Officer in a quandary. - The court found that the issue of comparability regarding one company was left open for the ITAT's consideration, while another company's matter was remitted to the TPO. - Ultimately, the court determined that the appeal of Revenue did not raise any substantial question of law and dismissed it accordingly.
Validity of order of ITAT allowing Applications filed u/s 254(2) - Rectification versus Review of order - TP Adjustment - The High court observed that the ITAT had rendered incompatible and inconsistent findings in its original order. - The court noted a contradiction between paragraphs 12 and 21 of the original order. - It was deemed necessary for the ITAT to recall its previous order and correct the error to avoid leaving the TPO and Assessing Officer in a quandary. - The court found that the issue of comparability regarding one company was left open for the ITAT's consideration, while another company's matter was remitted to the TPO. - Ultimately, the court determined that the appeal of Revenue did not raise any substantial question of law and dismissed it accordingly.
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