Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
The ITAT Hyderabad upheld the Corporate Guarantee Commission at 0.53% for guarantees to foreign AEs, rejecting the AO's 1.8% rate. The tribunal determined the pro rata guarantee at 30.50% of a $10 million loan balance. The CIT(A) classified corporate guarantees as international transactions and set the commission at 0.53%. Interest on trade receivables was benchmarked at 6% SBI rate. The tribunal remanded R&D, Head Office, and Marketing expenses issues back to the AO/TPO for fresh assessment, citing a violation of natural justice. The tribunal directed the assessee to provide segmental accounts for accurate benchmarking. The tribunal excluded certain comparables based on RPT filter agreement.
The ITAT Hyderabad upheld the Corporate Guarantee Commission at 0.53% for guarantees to foreign AEs, rejecting the AO's 1.8% rate. The tribunal determined the pro rata guarantee at 30.50% of a $10 million loan balance. The CIT(A) classified corporate guarantees as international transactions and set the commission at 0.53%. Interest on trade receivables was benchmarked at 6% SBI rate. The tribunal remanded R&D, Head Office, and Marketing expenses issues back to the AO/TPO for fresh assessment, citing a violation of natural justice. The tribunal directed the assessee to provide segmental accounts for accurate benchmarking. The tribunal excluded certain comparables based on RPT filter agreement.
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