Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verificat...
Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
The ITAT upheld the order of the CIT(A) regarding the Transfer Pricing (TP) adjustment. The Tribunal concurred with the CIT(A)'s decision to exclude two companies with exports while determining the Arm's Length range. It also agreed that the Tested Party, M/s. Laila Nutra, which is the Associated Enterprise (AE) of the assessee, can be compared only with the comparables selected by the Transfer Pricing Officer (TPO), as they are functionally broadly similar to the AE as a Tested Party. The ITAT dismissed the Revenue's grounds of appeal, finding no infirmity in the CIT(A)'s order.
The ITAT upheld the order of the CIT(A) regarding the Transfer Pricing (TP) adjustment. The Tribunal concurred with the CIT(A)'s decision to exclude two companies with exports while determining the Arm's Length range. It also agreed that the Tested Party, M/s. Laila Nutra, which is the Associated Enterprise (AE) of the assessee, can be compared only with the comparables selected by the Transfer Pricing Officer (TPO), as they are functionally broadly similar to the AE as a Tested Party. The ITAT dismissed the Revenue's grounds of appeal, finding no infirmity in the CIT(A)'s order.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
