Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The Appellate Tribunal (ITAT) considered Transfer Pricing (TP) adjustments related to foreign exchange gains and engineering services. The assessee used Transactional Net Margin Method (TNMM) while the Transfer Pricing Officer (TPO) applied Resale Price Method (RPM). The Dispute Resolution Panel (DRP) granted partial relief to the assessee, which was followed by the Assessing Officer in the assessment order. The Tribunal found no evidence to challenge the Assessing Officer's or TPO's findings, thus upholding the assessment order and dismissing the assessee's appeal.
The Appellate Tribunal (ITAT) considered Transfer Pricing (TP) adjustments related to foreign exchange gains and engineering services. The assessee used Transactional Net Margin Method (TNMM) while the Transfer Pricing Officer (TPO) applied Resale Price Method (RPM). The Dispute Resolution Panel (DRP) granted partial relief to the assessee, which was followed by the Assessing Officer in the assessment order. The Tribunal found no evidence to challenge the Assessing Officer's or TPO's findings, thus upholding the assessment order and dismissing the assessee's appeal.
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