Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
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 4828 
Join Channel 
