Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
TP Adjustment - Addition of international transaction related to the demerger - The High court identified a jurisdictional overreach by the AO, who made an adjustment beyond the scope of the TPO's determination. It was noted that the TPO's order did not explicitly dictate the inclusion of the demerged business's value in the ALP calculation, rendering the AO's addition legally unsustainable. The judgement emphasized the sanctity of procedural adherence and the delineated roles of the AO and TPO in the context of transfer pricing adjustments. - The Court set aside the impugned order and remanded the matter back to the AO.
TP Adjustment - Addition of international transaction related to the demerger - The High court identified a jurisdictional overreach by the AO, who made an adjustment beyond the scope of the TPO's determination. It was noted that the TPO's order did not explicitly dictate the inclusion of the demerged business's value in the ALP calculation, rendering the AO's addition legally unsustainable. The judgement emphasized the sanctity of procedural adherence and the delineated roles of the AO and TPO in the context of transfer pricing adjustments. - The Court set aside the impugned order and remanded the matter back to the AO.
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