Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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