Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
Transfer Pricing Adjustment - arm's length price (ALP) of international transactions- MAM - “other method” - The Tribunal analyzed the transfer pricing methods applied and found fault with the TPO's approach. It determined that the comparables used were not suitable, considering the functional dissimilarity with the assessee. Moreover, the rejection of the "other method" used by the assessee was deemed unjustified. Consequently, the Tribunal directed the deletion of the adjustment made by the TPO.
Transfer Pricing Adjustment - arm's length price (ALP) of international transactions- MAM - “other method” - The Tribunal analyzed the transfer pricing methods applied and found fault with the TPO's approach. It determined that the comparables used were not suitable, considering the functional dissimilarity with the assessee. Moreover, the rejection of the "other method" used by the assessee was deemed unjustified. Consequently, the Tribunal directed the deletion of the adjustment made by the TPO.
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