Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
The ITAT remanded the matter to the TPO for a fresh transfer pricing examination concerning the interest rate on ECB loans from the AE, directing the application of the FAR analysis in selecting comparables. The tribunal noted the absence of such analysis in prior proceedings and acknowledged the assessee's RBI approvals for payments to the AE. It emphasized that the TPO must consider RBI-prescribed interest rates relevant for benchmarking commercial borrowings during the relevant period. Consequently, the assessee's appeal was allowed for statistical purposes, mandating a reassessment consistent with these guidelines.
The ITAT remanded the matter to the TPO for a fresh transfer pricing examination concerning the interest rate on ECB loans from the AE, directing the application of the FAR analysis in selecting comparables. The tribunal noted the absence of such analysis in prior proceedings and acknowledged the assessee's RBI approvals for payments to the AE. It emphasized that the TPO must consider RBI-prescribed interest rates relevant for benchmarking commercial borrowings during the relevant period. Consequently, the assessee's appeal was allowed for statistical purposes, mandating a reassessment consistent with these guidelines.
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TaxTMI 
TaxTMI 
