Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
The ITAT held that M/s Automotive Stamping Assemblies Ltd. and M/s Majestic Ltd. should be accepted as comparable entities for TP analysis under TNMM as they were initially selected and not persistent loss-making companies. M/s Spicer India Pvt. Ltd. was rightly included despite related party transactions as TNMM requires broad comparability. For M/s JBM Auto Ltd., the issue was restored to the AO/TPO to re-adjudicate after examining segmental information. Forex losses/gains were held operating in nature being linked to import transactions. Economic adjustments were denied as not granted earlier by the Tribunal. The forex loss disallowance u/s 43A was restored to the AO for fresh adjudication based on bifurcation of capital and revenue components. The additional depreciation claim was dismissed as not claimed originally and being revenue neutral.
The ITAT held that M/s Automotive Stamping Assemblies Ltd. and M/s Majestic Ltd. should be accepted as comparable entities for TP analysis under TNMM as they were initially selected and not persistent loss-making companies. M/s Spicer India Pvt. Ltd. was rightly included despite related party transactions as TNMM requires broad comparability. For M/s JBM Auto Ltd., the issue was restored to the AO/TPO to re-adjudicate after examining segmental information. Forex losses/gains were held operating in nature being linked to import transactions. Economic adjustments were denied as not granted earlier by the Tribunal. The forex loss disallowance u/s 43A was restored to the AO for fresh adjudication based on bifurcation of capital and revenue components. The additional depreciation claim was dismissed as not claimed originally and being revenue neutral.
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