Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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...
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The ITAT allowed the assessee's appeal, directing the AO to reconsider multiple transfer pricing and tax-related adjustments. Key holdings include: (1) deletion of TP adjustments in SWD and test/measurement equipment segments, (2) accepting the assessee's profit level indicator methodology, (3) setting interest rate at LIBOR + 200 basis points, (4) directing reassessment of CSR expenditure under section 80G, (5) remanding long-term capital gain computation for fresh hearing, and (6) instructing verification of TDS credit from merged entity. The tribunal comprehensively upheld the assessee's contentions, providing procedural relief and mandating detailed reconsideration by lower authorities.
The ITAT allowed the assessee's appeal, directing the AO to reconsider multiple transfer pricing and tax-related adjustments. Key holdings include: (1) deletion of TP adjustments in SWD and test/measurement equipment segments, (2) accepting the assessee's profit level indicator methodology, (3) setting interest rate at LIBOR + 200 basis points, (4) directing reassessment of CSR expenditure under section 80G, (5) remanding long-term capital gain computation for fresh hearing, and (6) instructing verification of TDS credit from merged entity. The tribunal comprehensively upheld the assessee's contentions, providing procedural relief and mandating detailed reconsideration by lower authorities.
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