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...
The ITAT ruled against treating notional costs of services provided by the associated enterprise as part of operating expenses when calculating the assessee's PLI. The Tribunal noted that Rule 10TA (which includes share-based compensation as operating expenses) applies prospectively from April 1, 2017, and only when safe harbor rules are opted for, which was not the case here. The ITAT also applied the principle of consistency since no such adjustments were made in previous assessment years under similar circumstances. Regarding comparable selection, the matter was remanded to the TPO for fresh adjudication. For overdue receivables from AE, the Tribunal held that LIBOR+200 points should apply rather than PLR rates. The ITAT allowed interest expenses on CCDs but upheld disallowance of delayed PF contributions following the Supreme Court's Checkmate Services judgment.
The ITAT ruled against treating notional costs of services provided by the associated enterprise as part of operating expenses when calculating the assessee's PLI. The Tribunal noted that Rule 10TA (which includes share-based compensation as operating expenses) applies prospectively from April 1, 2017, and only when safe harbor rules are opted for, which was not the case here. The ITAT also applied the principle of consistency since no such adjustments were made in previous assessment years under similar circumstances. Regarding comparable selection, the matter was remanded to the TPO for fresh adjudication. For overdue receivables from AE, the Tribunal held that LIBOR+200 points should apply rather than PLR rates. The ITAT allowed interest expenses on CCDs but upheld disallowance of delayed PF contributions following the Supreme Court's Checkmate Services judgment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
