Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
This is a summary of an Income Tax Appellate Tribunal (ITAT) order dealing with various transfer pricing and deduction issues. The key points are: Transfer pricing adjustments were deleted for trademark fee, outstanding receivables, and purchase of finished goods transactions based on the application of appropriate methods and factual findings. The regional service charges and accounting support services transactions were remitted to the Transfer Pricing Officer for fresh adjudication after considering the assessee's submissions. The disallowance of 30% advertising and brand-building expenses was decided in favor of the assessee, following earlier years' ITAT orders. The disallowance of employees' contribution to ESI was upheld based on the Supreme Court's decision in Checkmate Services, as the contributions were deposited after the due dates prescribed under the relevant Act.
This is a summary of an Income Tax Appellate Tribunal (ITAT) order dealing with various transfer pricing and deduction issues. The key points are: Transfer pricing adjustments were deleted for trademark fee, outstanding receivables, and purchase of finished goods transactions based on the application of appropriate methods and factual findings. The regional service charges and accounting support services transactions were remitted to the Transfer Pricing Officer for fresh adjudication after considering the assessee's submissions. The disallowance of 30% advertising and brand-building expenses was decided in favor of the assessee, following earlier years' ITAT orders. The disallowance of employees' contribution to ESI was upheld based on the Supreme Court's decision in Checkmate Services, as the contributions were deposited after the due dates prescribed under the relevant Act.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
