Form 26AS evidence requires successor-entity accounting verification after business transfer, while invoice-supported related-party advertising expend...
Money-laundering judgment timing requires awaiting the scheduled-offence decision despite continuation of the underlying trial where outcomes directly...
Accredited investor eligibility expands through securities-market exposure, while alternative investment fund disputes require prescribed resolution a...
Customs Assessment Portal centralises classification and valuation guidance to support consistent, transparent and informed compliance across stakehol...
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ITAT adjudicated multiple transfer pricing issues, primarily focusing on comparability and arm's length pricing. The tribunal upheld the deletion of AMP expenditure additions, finding no international transaction. The court rejected Syngene International Limited as a comparable due to unavailable segmental information. Sequent Research Limited was accepted as a valid comparable. Regarding interest on external commercial borrowings, the tribunal remanded the matter to obtain proper credit ratings, agreeing that LIBOR was an appropriate benchmarking method. The TP adjustment on raw material purchases was deleted after analyzing gross margins, with the assessee's margin of 54.59% deemed acceptable compared to the comparable companies' median of 35.28%. Most revenue grounds were dismissed, with appeals allowed for statistical purposes.
ITAT adjudicated multiple transfer pricing issues, primarily focusing on comparability and arm's length pricing. The tribunal upheld the deletion of AMP expenditure additions, finding no international transaction. The court rejected Syngene International Limited as a comparable due to unavailable segmental information. Sequent Research Limited was accepted as a valid comparable. Regarding interest on external commercial borrowings, the tribunal remanded the matter to obtain proper credit ratings, agreeing that LIBOR was an appropriate benchmarking method. The TP adjustment on raw material purchases was deleted after analyzing gross margins, with the assessee's margin of 54.59% deemed acceptable compared to the comparable companies' median of 35.28%. Most revenue grounds were dismissed, with appeals allowed for statistical purposes.
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