Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
ITAT addressed multiple transfer pricing issues in an international business case. TPO was directed to reassess arm's-length pricing for trading segment transactions, allowing foreign AE as tested party if reliably substantiated. For intragroup services valued at nil, matter returned to TPO to evaluate service necessity, rendition, and economic benefit, excluding shareholder or duplicative services. Interest adjustment on delayed receivables upheld as separate international transaction, rejecting COVID-19 extension application. Store closure expenses disallowance reversed as expenditures were proven business-related. Set-off of brought forward business losses and unabsorbed depreciation allowed subject to legal compliance. TPO must provide fair hearing opportunity while determining revised arm's-length pricing.
ITAT addressed multiple transfer pricing issues in an international business case. TPO was directed to reassess arm's-length pricing for trading segment transactions, allowing foreign AE as tested party if reliably substantiated. For intragroup services valued at nil, matter returned to TPO to evaluate service necessity, rendition, and economic benefit, excluding shareholder or duplicative services. Interest adjustment on delayed receivables upheld as separate international transaction, rejecting COVID-19 extension application. Store closure expenses disallowance reversed as expenditures were proven business-related. Set-off of brought forward business losses and unabsorbed depreciation allowed subject to legal compliance. TPO must provide fair hearing opportunity while determining revised arm's-length pricing.
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