Anti-profiteering obligations survive business demerger, complaint withdrawal, and customized supply arrangements where rate-reduction benefits are no...
Road restoration charges constitute taxable services when requested for commercial pipeline activity, requiring reverse-charge GST from the business r...
Interest on delayed release of requisitioned cash includes statutory pre-assessment interest and restitutionary compensation for unlawful post-assessm...
Incomplete inventory records justify rejecting accounts, while profit estimation requires relevant comparable material and interest falls under other ...
Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
The ITAT allowed the appeal of the assessee, holding forex derivative losses were bona fide hedging business losses, not speculative, and directed their allowance; an ad-hoc 1% stock discrepancy addition was deleted. The DRP's fresh disallowance raised a new issue not examined by the AO and was held ultra vires; the DRP exceeded its jurisdiction by introducing a new source of income. Transfer pricing adjustments were restricted to LIBOR-based interest on loans to AEs, following coordinate-bench precedent. The Tribunal held notional interest on delayed receivables was not an international transaction for the relevant years and disallowed corresponding TP adjustment. The AO was directed to compute notional commission on a corporate guarantee at 1% interest.
The ITAT allowed the appeal of the assessee, holding forex derivative losses were bona fide hedging business losses, not speculative, and directed their allowance; an ad-hoc 1% stock discrepancy addition was deleted. The DRP's fresh disallowance raised a new issue not examined by the AO and was held ultra vires; the DRP exceeded its jurisdiction by introducing a new source of income. Transfer pricing adjustments were restricted to LIBOR-based interest on loans to AEs, following coordinate-bench precedent. The Tribunal held notional interest on delayed receivables was not an international transaction for the relevant years and disallowed corresponding TP adjustment. The AO was directed to compute notional commission on a corporate guarantee at 1% interest.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
