Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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