Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
