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...
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ITAT dismissed assessee's appeal on two grounds. Regarding transfer pricing adjustment on corporate guarantee commission, Tribunal upheld TPO's determination that providing corporate guarantees to associated enterprises constitutes international transactions requiring arm's length pricing. TPO properly applied comparable uncontrolled price method using bank guarantee commission rates with prudent 0.5% downward adjustment for risk differentials. Assessee failed to demonstrate any infirmity in TPO's methodology or comparable selection. On income classification, Tribunal confirmed DRP's ruling that interest on income-tax refund belongs under "Income from Other Sources" rather than business income, as such interest constitutes statutory compensation for delayed refund without nexus to business operations, not arising from commercial activities.
ITAT dismissed assessee's appeal on two grounds. Regarding transfer pricing adjustment on corporate guarantee commission, Tribunal upheld TPO's determination that providing corporate guarantees to associated enterprises constitutes international transactions requiring arm's length pricing. TPO properly applied comparable uncontrolled price method using bank guarantee commission rates with prudent 0.5% downward adjustment for risk differentials. Assessee failed to demonstrate any infirmity in TPO's methodology or comparable selection. On income classification, Tribunal confirmed DRP's ruling that interest on income-tax refund belongs under "Income from Other Sources" rather than business income, as such interest constitutes statutory compensation for delayed refund without nexus to business operations, not arising from commercial activities.
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