Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
ITAT remanded the transfer pricing (TP) adjustment matter relating to support services payment to AO for fresh consideration, finding that TPO erroneously rejected the Transactional Net Margin Method (TNMM) as the Most Appropriate Method (MAM). Regarding Section 10AA deduction for Special Economic Zone (SEZ) services, the Tribunal held that services provided to foreign customers involving warehousing, logistics, and handling qualify under SEZ Act definitions. The Tribunal directed the AO to delete disallowances, noting prior assessments had accepted the deduction's eligibility, and finding the services met statutory requirements for claiming deduction under Section 10AA of the Income Tax Act.
ITAT remanded the transfer pricing (TP) adjustment matter relating to support services payment to AO for fresh consideration, finding that TPO erroneously rejected the Transactional Net Margin Method (TNMM) as the Most Appropriate Method (MAM). Regarding Section 10AA deduction for Special Economic Zone (SEZ) services, the Tribunal held that services provided to foreign customers involving warehousing, logistics, and handling qualify under SEZ Act definitions. The Tribunal directed the AO to delete disallowances, noting prior assessments had accepted the deduction's eligibility, and finding the services met statutory requirements for claiming deduction under Section 10AA of the Income Tax Act.
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