Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
The ITAT upheld the TP adjustment for software development services to AE. L&T Infotech was considered comparable, rejecting appellant's argument. Persistent Systems Ltd's exclusion request was denied as it was part of the final comparables list. Imputing interest on receivables should use prevailing Indian rates or LIBOR with markup. The case law supports market-determined rates for benchmarking. Disallowance of employee PF contribution was upheld u/s 36(1)(va) u/s 2(24)(x) based on Checkmate Services case, stating belated remittance is not deductible even if paid before the return filing due date.
The ITAT upheld the TP adjustment for software development services to AE. L&T Infotech was considered comparable, rejecting appellant's argument. Persistent Systems Ltd's exclusion request was denied as it was part of the final comparables list. Imputing interest on receivables should use prevailing Indian rates or LIBOR with markup. The case law supports market-determined rates for benchmarking. Disallowance of employee PF contribution was upheld u/s 36(1)(va) u/s 2(24)(x) based on Checkmate Services case, stating belated remittance is not deductible even if paid before the return filing due date.
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