Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
ITAT partially allowed the assessee's appeal across multiple tax-related issues. The Tribunal directed the AO to: (1) determine arm's length pricing for royalty payments using TNMM method, (2) recompute interest on outstanding receivables using LIBOR+200 points, (3) delete gratuity expenses disallowance under section 43B, (4) verify and grant foreign tax credit with proper documentation, (5) review Dividend Distribution Tax credit and related interest calculations, and (6) substantiate or remove ad-hoc interest levy. The decision emphasizes procedural fairness, statutory compliance, and principled tax assessment, allowing most grounds of appeal for statistical purposes with specific directional instructions to the Assessing Officer.
ITAT partially allowed the assessee's appeal across multiple tax-related issues. The Tribunal directed the AO to: (1) determine arm's length pricing for royalty payments using TNMM method, (2) recompute interest on outstanding receivables using LIBOR+200 points, (3) delete gratuity expenses disallowance under section 43B, (4) verify and grant foreign tax credit with proper documentation, (5) review Dividend Distribution Tax credit and related interest calculations, and (6) substantiate or remove ad-hoc interest levy. The decision emphasizes procedural fairness, statutory compliance, and principled tax assessment, allowing most grounds of appeal for statistical purposes with specific directional instructions to the Assessing Officer.
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