Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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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