Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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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