Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
The HC declined to entertain the petition challenging the Tribunal's decision under Section 254(2) regarding TP adjustment for guarantee fees paid to an Associated Enterprise. The Court noted that the Tribunal had decided Ground No.4 in favor of the Assessee based on a precedent from the Gujarat HC [2018] that confirmed a similar ruling for an earlier assessment year (2009-10). The Court determined it would be an academic exercise to evaluate the Tribunal's power to recall its order under Section 254(2) when the HC had already approved similar findings in the previous assessment year, thereby implicitly validating the Tribunal's conclusion rejecting the upward TP adjustment of guarantee fees.
The HC declined to entertain the petition challenging the Tribunal's decision under Section 254(2) regarding TP adjustment for guarantee fees paid to an Associated Enterprise. The Court noted that the Tribunal had decided Ground No.4 in favor of the Assessee based on a precedent from the Gujarat HC [2018] that confirmed a similar ruling for an earlier assessment year (2009-10). The Court determined it would be an academic exercise to evaluate the Tribunal's power to recall its order under Section 254(2) when the HC had already approved similar findings in the previous assessment year, thereby implicitly validating the Tribunal's conclusion rejecting the upward TP adjustment of guarantee fees.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
