Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
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The ITAT dismissed the revenue's appeal against the CIT(A)'s order deleting the addition made u/s 28(iv) for assets received free of cost from the assessee's associated enterprise (AE). The assets were used by the assessee for providing services to its AE on a cost-plus basis, with depreciation on these assets included in the cost base per the Advance Pricing Agreement. As the assessee received remuneration from its AE after mark-up on this cost base, the ITAT held that no benefit arose to the assessee from using these assets provided by the AE. The ITAT also dismissed the other grounds raised by the revenue regarding reimbursement to seconded employees and the low tax effect, upholding the CIT(A)'s order.
The ITAT dismissed the revenue's appeal against the CIT(A)'s order deleting the addition made u/s 28(iv) for assets received free of cost from the assessee's associated enterprise (AE). The assets were used by the assessee for providing services to its AE on a cost-plus basis, with depreciation on these assets included in the cost base per the Advance Pricing Agreement. As the assessee received remuneration from its AE after mark-up on this cost base, the ITAT held that no benefit arose to the assessee from using these assets provided by the AE. The ITAT also dismissed the other grounds raised by the revenue regarding reimbursement to seconded employees and the low tax effect, upholding the CIT(A)'s order.
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