Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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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