Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Objective characteristics govern magnesium bis-glycinate chelate classification as an amino-acid coordination compound, not a food preparation or anti...
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The Appellate Tribunal considered TP adjustment on brokerage commission received from related parties. It found TNMM method appropriate for benchmarking the commission rates. Also, it held that higher commission rates for non-related parties should be arm's length for related parties. The Tribunal allowed the appeal, holding TNMM as the preferred method. Regarding royalty payments, the Tribunal upheld TNMM method for benchmarking, rejecting internal CUP and external CUP due to lack of comparable data. Indirect cost reimbursement was scrutinized, with the Tribunal directing deletion of the addition made by AO/TPO. Additionally, the Tribunal ruled in favor of the assessee for outstanding securities tax and TDS issues, directing deletions of disallowances. The Tribunal allowed the appeal on various grounds, maintaining consistency with prior rulings.
The Appellate Tribunal considered TP adjustment on brokerage commission received from related parties. It found TNMM method appropriate for benchmarking the commission rates. Also, it held that higher commission rates for non-related parties should be arm's length for related parties. The Tribunal allowed the appeal, holding TNMM as the preferred method. Regarding royalty payments, the Tribunal upheld TNMM method for benchmarking, rejecting internal CUP and external CUP due to lack of comparable data. Indirect cost reimbursement was scrutinized, with the Tribunal directing deletion of the addition made by AO/TPO. Additionally, the Tribunal ruled in favor of the assessee for outstanding securities tax and TDS issues, directing deletions of disallowances. The Tribunal allowed the appeal on various grounds, maintaining consistency with prior rulings.
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