Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
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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TaxTMI 
TaxTMI 
of 4915 
