Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Development rights transfers treated as immovable property, while construction abatement applies and repeated non-payment permits extended service-tax...
The ITAT deleted the Transfer Pricing adjustment relating to AMP expenses incurred by the appellant as an international transaction under section 92B. The tribunal relied on its coordinate bench's precedent, holding that since the appellant demonstrated arm's length remuneration from distribution services, including subvention income exceeding the adjustment amount, no further addition was justified. The TPO's reliance on the Bright Line Test was rejected as lacking statutory basis. Consequently, the impugned Transfer Pricing adjustment was set aside, and the appellant's appeal on this ground was allowed.
The ITAT deleted the Transfer Pricing adjustment relating to AMP expenses incurred by the appellant as an international transaction under section 92B. The tribunal relied on its coordinate bench's precedent, holding that since the appellant demonstrated arm's length remuneration from distribution services, including subvention income exceeding the adjustment amount, no further addition was justified. The TPO's reliance on the Bright Line Test was rejected as lacking statutory basis. Consequently, the impugned Transfer Pricing adjustment was set aside, and the appellant's appeal on this ground was allowed.
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