Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
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The ITAT held that the assessee, providing limited logistics and administrative services without inventory holding or significant value addition, qualifies as a low-risk distributor. The Tribunal accepted the assessee's application of the Berry ratio for determining the ALP in the distribution segment, rejecting the AO/TPO's adjustment based on PLI under TNMM. It was directed that cost of goods be excluded from the denominator while computing PLI. Consequently, adjustments made by the AO/TPO in both distribution and manufacturing segments were deleted. Regarding interest under section 234A, the AO was instructed to verify if the return was filed within the extended deadline under CBDT Circular No.1/2022; if so, no interest would be leviable. Grounds 4 to 8 raised by the assessee were allowed, with the interest claim partly allowed for statistical purposes.
The ITAT held that the assessee, providing limited logistics and administrative services without inventory holding or significant value addition, qualifies as a low-risk distributor. The Tribunal accepted the assessee's application of the Berry ratio for determining the ALP in the distribution segment, rejecting the AO/TPO's adjustment based on PLI under TNMM. It was directed that cost of goods be excluded from the denominator while computing PLI. Consequently, adjustments made by the AO/TPO in both distribution and manufacturing segments were deleted. Regarding interest under section 234A, the AO was instructed to verify if the return was filed within the extended deadline under CBDT Circular No.1/2022; if so, no interest would be leviable. Grounds 4 to 8 raised by the assessee were allowed, with the interest claim partly allowed for statistical purposes.
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