Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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