Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
ITAT partially allowed assessee's appeal, affirming arm's-length royalty payments and consultancy service expenses based on consistent prior year rulings. The tribunal directed deletion of transfer pricing adjustments related to expatriate costs and reimbursements. Regarding income tax liability provision, the tribunal accepted the assessee's contention that reversal of previously disallowed provision should not result in double taxation, allowing the ground subject to AO's verification. The decision upholds procedural fairness and prevents duplicative tax treatment of contingent liabilities.
ITAT partially allowed assessee's appeal, affirming arm's-length royalty payments and consultancy service expenses based on consistent prior year rulings. The tribunal directed deletion of transfer pricing adjustments related to expatriate costs and reimbursements. Regarding income tax liability provision, the tribunal accepted the assessee's contention that reversal of previously disallowed provision should not result in double taxation, allowing the ground subject to AO's verification. The decision upholds procedural fairness and prevents duplicative tax treatment of contingent liabilities.
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