Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
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...
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TP Adjustment - MAM - Management consultancy services - The tribunal noted discrepancies in how services were valued between Associated Enterprises (AE) and Non-AEs. The CUP method was initially rejected by the TPO in favor of TNMM, citing lack of stringent comparability. However, the tribunal supported the appellant's use of CUP, observing that internal comparables provided a reasonable basis for determining arm's length prices.
TP Adjustment - MAM - Management consultancy services - The tribunal noted discrepancies in how services were valued between Associated Enterprises (AE) and Non-AEs. The CUP method was initially rejected by the TPO in favor of TNMM, citing lack of stringent comparability. However, the tribunal supported the appellant's use of CUP, observing that internal comparables provided a reasonable basis for determining arm's length prices.
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