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 ruled that CUP method was inapplicable for transfer pricing adjustment due to fundamental differences not reasonably adjustable, holding TNMM as most appropriate method under Rule 10C(2) read with Rule 10B(1)(e). The assessee obtained license from international breeder for specialized potato cultivation, while the related entity merely coordinated contract farming activities. ITAT determined the related entity as tested party being a simple trader without intangibles, versus assessee as complex entity possessing know-how. Purchase transactions at cost-plus markup were held at arm's length based on comparable margins from reliable databases. Transfer pricing adjustment was deleted, rendering penalty proceedings under sections 270A and 271AA infructuous. Matter regarding book profits computation under section 115JB was remanded for verification and appropriate relief.
ITAT ruled that CUP method was inapplicable for transfer pricing adjustment due to fundamental differences not reasonably adjustable, holding TNMM as most appropriate method under Rule 10C(2) read with Rule 10B(1)(e). The assessee obtained license from international breeder for specialized potato cultivation, while the related entity merely coordinated contract farming activities. ITAT determined the related entity as tested party being a simple trader without intangibles, versus assessee as complex entity possessing know-how. Purchase transactions at cost-plus markup were held at arm's length based on comparable margins from reliable databases. Transfer pricing adjustment was deleted, rendering penalty proceedings under sections 270A and 271AA infructuous. Matter regarding book profits computation under section 115JB was remanded for verification and appropriate relief.
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