Opportunity to respond to jurisdictional reports is mandatory before customs settlement duty enhancement; connected applications require consistent ad...
Specific customs headings for scaffolding components prevail over general classification, invalidating misclassification proceedings and enabling with...
Liquidator appointment under Section 34 requires consideration of creditor recommendations, valid professional authorisation, and preservation of vali...
Income-tax exemption for specified regulatory fees and government grants applies subject to non-commercial activity and continuing compliance conditio...
Digital accessibility audit and remediation deadlines extended, while all other disability-compliance obligations for regulated entities remain unchan...
The ITAT provided the following rulings: Regarding TP adjustment for comparable selection and treatment of IT support services as ITeS, the issue requires examination by the Transfer Pricing Officer (TPO) based on the specific nature of services rendered by the assessee. Concerning the TPO's separate benchmarking analysis for cost contribution charges and determining arm's length price at 'Nil', making an adjustment of the entire amount, the ITAT ruled in favor of the assessee. The Tribunal held that the TPO remained oblivious to Rule 10B(1)(a) stipulating 'comparable' and 'uncontrolled' transactions while applying the CUP method, and the TPO's general observation was incorrect. The ITAT directed the TPO to delete additions made on account of cost contribution charges and notional interest on outstanding receivables from Associated Enterprises (AEs).
The ITAT provided the following rulings: Regarding TP adjustment for comparable selection and treatment of IT support services as ITeS, the issue requires examination by the Transfer Pricing Officer (TPO) based on the specific nature of services rendered by the assessee. Concerning the TPO's separate benchmarking analysis for cost contribution charges and determining arm's length price at 'Nil', making an adjustment of the entire amount, the ITAT ruled in favor of the assessee. The Tribunal held that the TPO remained oblivious to Rule 10B(1)(a) stipulating 'comparable' and 'uncontrolled' transactions while applying the CUP method, and the TPO's general observation was incorrect. The ITAT directed the TPO to delete additions made on account of cost contribution charges and notional interest on outstanding receivables from Associated Enterprises (AEs).
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