Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
ITAT held that the final assessment order was void ab initio due to non-compliance with DRP directions under Section 144C(13). The tribunal found the Assessing Officer (AO) did not follow specific procedural requirements, rendering the assessment order invalid. Regarding intra-group services (IGS), the tribunal allowed the assessee's claim, determining that the payments were genuine, made without markup, and benchmarked appropriately. The tribunal emphasized that tax authorities cannot question expenses when transactions are legitimate and serve business purposes. The disallowance of intra-group service charges was consequently deleted, upholding the arm's length principle and rejecting the need for a strict tangible commercial benefit test.
ITAT held that the final assessment order was void ab initio due to non-compliance with DRP directions under Section 144C(13). The tribunal found the Assessing Officer (AO) did not follow specific procedural requirements, rendering the assessment order invalid. Regarding intra-group services (IGS), the tribunal allowed the assessee's claim, determining that the payments were genuine, made without markup, and benchmarked appropriately. The tribunal emphasized that tax authorities cannot question expenses when transactions are legitimate and serve business purposes. The disallowance of intra-group service charges was consequently deleted, upholding the arm's length principle and rejecting the need for a strict tangible commercial benefit test.
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