Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
ITAT rejected the TPO's approach of aggregating all international transactions for transfer pricing analysis. The Tribunal found that the TPO improperly combined payment and receipt of intra-group services (IGS) using the same OP/OC or OP/OR benchmarking metrics, despite the assessee maintaining separate "Craft division" accounts. The TPO failed to provide adequate opportunity for the assessee to substantiate its cost allocation basis between divisions. The matter was remanded to the TPO to conduct separate benchmarking for services rendered and received using appropriate methods (TNMM or CUP) under Rule 10D. The appeal was decided in favor of the assessee for statistical purposes.
ITAT rejected the TPO's approach of aggregating all international transactions for transfer pricing analysis. The Tribunal found that the TPO improperly combined payment and receipt of intra-group services (IGS) using the same OP/OC or OP/OR benchmarking metrics, despite the assessee maintaining separate "Craft division" accounts. The TPO failed to provide adequate opportunity for the assessee to substantiate its cost allocation basis between divisions. The matter was remanded to the TPO to conduct separate benchmarking for services rendered and received using appropriate methods (TNMM or CUP) under Rule 10D. The appeal was decided in favor of the assessee for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
