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...
Transfer pricing adjustments, selection of the most appropriate method (MAM), benchmarking approach (aggregation or segregation), factual rendering of services, arm's length pricing (ALP) determination for various transactions like Technical Support Services (TSS), Business Support Services (BSS), and royalty payments. It highlights the inconsistencies in the approach adopted by the Transfer Pricing Officer (TPO) and the Dispute Resolution Panel (DRP) compared to previous years, lack of proper consideration of evidence and contentions raised by the assessee, and the need for remitting the matter back to the TPO for a fresh determination considering all relevant factors, including landed cost of imported components for comparables in the case of royalty transactions.
Transfer pricing adjustments, selection of the most appropriate method (MAM), benchmarking approach (aggregation or segregation), factual rendering of services, arm's length pricing (ALP) determination for various transactions like Technical Support Services (TSS), Business Support Services (BSS), and royalty payments. It highlights the inconsistencies in the approach adopted by the Transfer Pricing Officer (TPO) and the Dispute Resolution Panel (DRP) compared to previous years, lack of proper consideration of evidence and contentions raised by the assessee, and the need for remitting the matter back to the TPO for a fresh determination considering all relevant factors, including landed cost of imported components for comparables in the case of royalty transactions.
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