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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
ITAT ruled against the TPO's adjustment regarding interest on outstanding receivables from associated enterprises. The Tribunal determined the transactions were not "international transactions" under transfer pricing regulations as the assessee was properly compensated by its AE, maintained a debt-free status, and had no actual finance costs related to borrowings. The average credit period of 92 days fell below the industry average of 105 days, indicating no excessive delay in remittances that would suggest the AE was enjoying unreasonable credit facilities. Following Bechtel India precedent, ITAT concluded the revenue failed to demonstrate any benefit transfer to the AE and directed deletion of the proposed additions.
ITAT ruled against the TPO's adjustment regarding interest on outstanding receivables from associated enterprises. The Tribunal determined the transactions were not "international transactions" under transfer pricing regulations as the assessee was properly compensated by its AE, maintained a debt-free status, and had no actual finance costs related to borrowings. The average credit period of 92 days fell below the industry average of 105 days, indicating no excessive delay in remittances that would suggest the AE was enjoying unreasonable credit facilities. Following Bechtel India precedent, ITAT concluded the revenue failed to demonstrate any benefit transfer to the AE and directed deletion of the proposed additions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
