Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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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