Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
The ITAT held that the arm's length price of salary paid to global sales personnel, being intrinsically linked to software product sales to the AE and benchmarked via the TNMM method accepted by the TPO, should not be separately adjusted. Consequently, the TPO's downward TP adjustment on the salary cross-charge was deleted. Regarding the adjustment under section 143(1), the tribunal noted the pending rectification application and appeal filed by the assessee, directing the AO and FAA to dispose of both expeditiously. The order thus restores the salary payment treatment within the overall TNMM benchmarking and mandates prompt adjudication of related procedural matters.
The ITAT held that the arm's length price of salary paid to global sales personnel, being intrinsically linked to software product sales to the AE and benchmarked via the TNMM method accepted by the TPO, should not be separately adjusted. Consequently, the TPO's downward TP adjustment on the salary cross-charge was deleted. Regarding the adjustment under section 143(1), the tribunal noted the pending rectification application and appeal filed by the assessee, directing the AO and FAA to dispose of both expeditiously. The order thus restores the salary payment treatment within the overall TNMM benchmarking and mandates prompt adjudication of related procedural matters.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
