Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to Income Tax Appellate Tribunal (ITAT) and Dispute Resolution Panel (DRP) directions. TP adjustment should only consider transactions with associated enterprises (AEs), as per transfer pricing regulations and Chapter X of the Income Tax Act. ITAT directed assessing officer (AO)/TPO to rectify by considering only AE transactions for TP adjustment computation, without circumventing ITAT and DRP directions. Assessee's appeal allowed for statistical purposes.
Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to Income Tax Appellate Tribunal (ITAT) and Dispute Resolution Panel (DRP) directions. TP adjustment should only consider transactions with associated enterprises (AEs), as per transfer pricing regulations and Chapter X of the Income Tax Act. ITAT directed assessing officer (AO)/TPO to rectify by considering only AE transactions for TP adjustment computation, without circumventing ITAT and DRP directions. Assessee's appeal allowed for statistical purposes.
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