Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
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The ITAT allowed the revenue's appeal for statistical purposes and remitted the matter back to the Assessing Officer to re-examine the issue and refer it to the Transfer Pricing Officer (TPO) for determination of arm's length price based on the most suitable method. The ITAT observed that the assessee neither provided detailed workings for the Comparable Uncontrolled Price (CUP) method to the Commissioner of Income Tax (Appeals) nor did the CIT(A) perform any such calculation. The ITAT found force in the revenue's argument that since the assessee did not provide services to any party other than its Associated Enterprises (AEs) nor awarded any sub-contract to independent entities, no internal comparables were available for working under the CUP method. The ITAT distinguished the case relied upon by the assessee, as in that case, the ALP was computed by the assessee itself following the CUP method, whereas in the present case, no precise workings were provided for either CUP or Transactional Net Margin Method (TNMM).
The ITAT allowed the revenue's appeal for statistical purposes and remitted the matter back to the Assessing Officer to re-examine the issue and refer it to the Transfer Pricing Officer (TPO) for determination of arm's length price based on the most suitable method. The ITAT observed that the assessee neither provided detailed workings for the Comparable Uncontrolled Price (CUP) method to the Commissioner of Income Tax (Appeals) nor did the CIT(A) perform any such calculation. The ITAT found force in the revenue's argument that since the assessee did not provide services to any party other than its Associated Enterprises (AEs) nor awarded any sub-contract to independent entities, no internal comparables were available for working under the CUP method. The ITAT distinguished the case relied upon by the assessee, as in that case, the ALP was computed by the assessee itself following the CUP method, whereas in the present case, no precise workings were provided for either CUP or Transactional Net Margin Method (TNMM).
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