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...
The ITAT Mumbai held that the Transfer Pricing Officer (TPO) unjustifiably rejected the benchmarking analysis done by the assessee for determining the Arm's Length Price (ALP) of services. The TPO's adhoc estimation lacked proper basis and reasoning, while the assessee's detailed analysis and need and benefit test were found to be satisfactory. The TPO's rejection of the benchmarking using the associated enterprise as a tested party was deemed incorrect, as the foreign associated enterprise was accepted as a tested party for benchmarking. The TPO's adhoc determination of TP adjustment was rejected, and the MAT credit entitlement issue was directed for further verification. The disallowance under section 14A r.w.r. 8D was deleted as the assessee did not claim dividend income as exempt.
The ITAT Mumbai held that the Transfer Pricing Officer (TPO) unjustifiably rejected the benchmarking analysis done by the assessee for determining the Arm's Length Price (ALP) of services. The TPO's adhoc estimation lacked proper basis and reasoning, while the assessee's detailed analysis and need and benefit test were found to be satisfactory. The TPO's rejection of the benchmarking using the associated enterprise as a tested party was deemed incorrect, as the foreign associated enterprise was accepted as a tested party for benchmarking. The TPO's adhoc determination of TP adjustment was rejected, and the MAT credit entitlement issue was directed for further verification. The disallowance under section 14A r.w.r. 8D was deleted as the assessee did not claim dividend income as exempt.
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