Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
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The ITAT directed the AO to treat the excess consideration paid in slump sale transactions as goodwill and allow depreciation accordingly, following a coordinate bench's precedent. The tribunal allowed the set-off of brought forward unabsorbed depreciation, distinguishing it from business loss. Transfer Pricing adjustments on AMP expenses were disallowed due to lack of evidence of association or statutory basis for the Bright Line Test. The tribunal directed inclusion of Satyatej Commercial Co. Ltd. as a comparable for import of finished goods transactions, excluding freight costs. It also ordered exclusion of Hand Innovations Inc. and RG Medical Diagnostics for benchmarking indenting commission transactions based on product and territorial similarity. The tribunal held that reimbursement of expenses could not be valued at nil without independent comparable evidence and disallowed the TPO's and DRP's treatment, allowing the related appeal ground. All contested grounds raised by the assessee were allowed accordingly.
The ITAT directed the AO to treat the excess consideration paid in slump sale transactions as goodwill and allow depreciation accordingly, following a coordinate bench's precedent. The tribunal allowed the set-off of brought forward unabsorbed depreciation, distinguishing it from business loss. Transfer Pricing adjustments on AMP expenses were disallowed due to lack of evidence of association or statutory basis for the Bright Line Test. The tribunal directed inclusion of Satyatej Commercial Co. Ltd. as a comparable for import of finished goods transactions, excluding freight costs. It also ordered exclusion of Hand Innovations Inc. and RG Medical Diagnostics for benchmarking indenting commission transactions based on product and territorial similarity. The tribunal held that reimbursement of expenses could not be valued at nil without independent comparable evidence and disallowed the TPO's and DRP's treatment, allowing the related appeal ground. All contested grounds raised by the assessee were allowed accordingly.
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