Liquidator appointment under Section 34 requires consideration of creditor recommendations, valid professional authorisation, and preservation of vali...
Income-tax exemption for specified regulatory fees and government grants applies subject to non-commercial activity and continuing compliance conditio...
Digital accessibility audit and remediation deadlines extended, while all other disability-compliance obligations for regulated entities remain unchan...
The ITAT upheld the CIT(A)'s order, dismissing the Revenue's appeals. It held that a corporate guarantee given by the assessee for its AE, without incurring expenditure, does not constitute an international transaction under section 92B. Regarding transfer pricing adjustments on instant coffee supplied in multiple sizes, the Tribunal found the TPO's selective comparison of only two sizes arbitrary and accepted the assessee's explanation of comparable pricing across all sizes, negating profit shifting. On interest for delayed receivables from AEs, the ITAT concurred with the CIT(A) that no undue credit advantage existed, and no adjustment was warranted. Consequently, all additions proposed by the TPO were deleted, affirming the arm's length nature of the transactions.
The ITAT upheld the CIT(A)'s order, dismissing the Revenue's appeals. It held that a corporate guarantee given by the assessee for its AE, without incurring expenditure, does not constitute an international transaction under section 92B. Regarding transfer pricing adjustments on instant coffee supplied in multiple sizes, the Tribunal found the TPO's selective comparison of only two sizes arbitrary and accepted the assessee's explanation of comparable pricing across all sizes, negating profit shifting. On interest for delayed receivables from AEs, the ITAT concurred with the CIT(A) that no undue credit advantage existed, and no adjustment was warranted. Consequently, all additions proposed by the TPO were deleted, affirming the arm's length nature of the transactions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
