Handicraft job work receives concessional GST only for registered principals and predominantly handmade goods; commercial resin articles remain taxabl...
Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination b...
Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
ITAT allowed in part. It held that payments by the appellant-company to the foreign service provider for business support services do not constitute FTS under s.9(1)(vii) and, in any event, are not taxable in India by application of s.90(2) and the India-Australia treaty; the AO's disallowance under s.40(a)(i) for non-deduction u/s195 was therefore deleted. On transfer-pricing, the Tribunal upheld that receivables from associated enterprises constitute international transactions requiring benchmarking; the assessee's contention of no imputed interest (and of netting payables) was rejected for want of specific reciprocal AE-wise details. The Tribunal directed computation of imputed interest on overdue AE receivables at LIBOR + 200 bps, thereby partly allowing the appeal.
ITAT allowed in part. It held that payments by the appellant-company to the foreign service provider for business support services do not constitute FTS under s.9(1)(vii) and, in any event, are not taxable in India by application of s.90(2) and the India-Australia treaty; the AO's disallowance under s.40(a)(i) for non-deduction u/s195 was therefore deleted. On transfer-pricing, the Tribunal upheld that receivables from associated enterprises constitute international transactions requiring benchmarking; the assessee's contention of no imputed interest (and of netting payables) was rejected for want of specific reciprocal AE-wise details. The Tribunal directed computation of imputed interest on overdue AE receivables at LIBOR + 200 bps, thereby partly allowing the appeal.
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