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 Adjustment - Arm's Length Adjustment to Income from Guarantee Commission - Income from Interest on Loans Advanced to Associated Enterprise - The Tribunal emphasized the need for proper benchmarking in determining the arm's length price for these transactions, directing remands to the Assessing Officer and Commissioner for reevaluation. Overall, the appeals were allowed for statistical purposes, with the Tribunal providing detailed instructions for reassessment based on appropriate benchmarks.
Transfer Pricing Adjustment - Arm's Length Adjustment to Income from Guarantee Commission - Income from Interest on Loans Advanced to Associated Enterprise - The Tribunal emphasized the need for proper benchmarking in determining the arm's length price for these transactions, directing remands to the Assessing Officer and Commissioner for reevaluation. Overall, the appeals were allowed for statistical purposes, with the Tribunal providing detailed instructions for reassessment based on appropriate benchmarks.
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