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...
ITAT dismissed grounds 1 and 2 regarding validity of assessment order, relying on Aztec Software precedent. The Tribunal allowed ground 3 concerning Intra Group Services, following a coordinate Bench decision in assessee's own case for AY 2010-11, as Revenue failed to demonstrate distinguishing features in the current assessment year. Similarly, ground 4 regarding disallowance of mark-up charged by AEs on fixed asset purchases was allowed, directing deletion of the ALP adjustment. Regarding royalty payments, ITAT rejected Revenue's appeal, citing EKL Appliances which negated the need-benefit test, and Magneti Marelli Powertrain which established that TPO cannot segregate transactions already aggregated and benchmarked under TNMM to reduce their ALP to nil under CUP method.
ITAT dismissed grounds 1 and 2 regarding validity of assessment order, relying on Aztec Software precedent. The Tribunal allowed ground 3 concerning Intra Group Services, following a coordinate Bench decision in assessee's own case for AY 2010-11, as Revenue failed to demonstrate distinguishing features in the current assessment year. Similarly, ground 4 regarding disallowance of mark-up charged by AEs on fixed asset purchases was allowed, directing deletion of the ALP adjustment. Regarding royalty payments, ITAT rejected Revenue's appeal, citing EKL Appliances which negated the need-benefit test, and Magneti Marelli Powertrain which established that TPO cannot segregate transactions already aggregated and benchmarked under TNMM to reduce their ALP to nil under CUP method.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
