PMLA anticipatory bail requires satisfaction of twin conditions, while predicate-offence protection does not extend to independent money-laundering pr...
School-affiliation charges remain taxable where not directly connected with examinations, while extended limitation requires proof of deliberate tax e...
The ITAT addressed multiple transfer pricing issues regarding an assessee's international transactions. On the KPO versus software developer classification dispute, ITAT left the matter open for future determination due to insufficient reasoning from TPO/DRP. Regarding corporate guarantee fees, ITAT modified the TPO's assessment of 1.90% to 0.53%, aligning with the Hetero Labs Limited precedent. The tribunal directed computation based on actual guarantee periods rather than annualized basis. For letters of comfort, ITAT determined these were equivalent to corporate guarantees and required similar benchmarking at 0.53%, rejecting the TPO's higher rate of 1.90%. The decision established parity between ECB rates (1.67%) and corporate guarantee charges, mandating the latter be substantially lower.
The ITAT addressed multiple transfer pricing issues regarding an assessee's international transactions. On the KPO versus software developer classification dispute, ITAT left the matter open for future determination due to insufficient reasoning from TPO/DRP. Regarding corporate guarantee fees, ITAT modified the TPO's assessment of 1.90% to 0.53%, aligning with the Hetero Labs Limited precedent. The tribunal directed computation based on actual guarantee periods rather than annualized basis. For letters of comfort, ITAT determined these were equivalent to corporate guarantees and required similar benchmarking at 0.53%, rejecting the TPO's higher rate of 1.90%. The decision established parity between ECB rates (1.67%) and corporate guarantee charges, mandating the latter be substantially lower.
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