Employee conflict disclosures and investment restrictions expand with new recusal duties, post-employment limits, and compliance reporting requirement...
Revenue-neutral domestic transfer pricing and mirror transactions justified deletion of related-party adjustments for operation, maintenance and port ...
ITAT held that transactions between the assessee and franchisees/LFS constitute principal-to-principal sales, not commission payments. The tribunal rejected revenue's contentions under Sections 194H and 194I, finding no evidence of commission or rental arrangement. Employees' temporary presence in LFS stores does not establish possession or control. The brand's market positioning through discounted pricing does not constitute commission. The tribunal found no merit in revenue's arguments and dismissed the appeal, upholding the lower appellate authority's order and maintaining the principal-to-principal sales characterization.
ITAT held that transactions between the assessee and franchisees/LFS constitute principal-to-principal sales, not commission payments. The tribunal rejected revenue's contentions under Sections 194H and 194I, finding no evidence of commission or rental arrangement. Employees' temporary presence in LFS stores does not establish possession or control. The brand's market positioning through discounted pricing does not constitute commission. The tribunal found no merit in revenue's arguments and dismissed the appeal, upholding the lower appellate authority's order and maintaining the principal-to-principal sales characterization.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
