Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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...
ITAT adjudicated a transfer pricing dispute involving comparability analysis and interest computation on outstanding receivables. The tribunal rejected certain comparator companies as functionally dissimilar. Regarding notional interest, ITAT held that TPO must conduct a comprehensive transfer pricing study considering credit periods and applicable LIBOR rates. The tribunal remanded the matter to the AO/TPO, directing that if working capital adjustment encompasses outstanding receivables, no separate characterization is required. For receivables outside working capital, the interest rate should be LIBOR plus 300 basis points, consistent with judicial precedent, with a 90-day credit consideration.
ITAT adjudicated a transfer pricing dispute involving comparability analysis and interest computation on outstanding receivables. The tribunal rejected certain comparator companies as functionally dissimilar. Regarding notional interest, ITAT held that TPO must conduct a comprehensive transfer pricing study considering credit periods and applicable LIBOR rates. The tribunal remanded the matter to the AO/TPO, directing that if working capital adjustment encompasses outstanding receivables, no separate characterization is required. For receivables outside working capital, the interest rate should be LIBOR plus 300 basis points, consistent with judicial precedent, with a 90-day credit consideration.
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