Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
The ITAT remitted and disposed issues as follows: directed recomputation of transfer-pricing interest on outstanding receivables at LIBOR + 0.65% (rejecting application of the Coordinate Bench's prior basis point and the CIT(A)'s LIBOR + 0.5%); deleted the TPO adjustment relating to interest on share-application monies where shares were allotted within six months; held that no disallowance under s.14A read with Rule 8D is sustainable because the assessee earned no exempt income and the 2022 amendment is prospective; and held that major overhauling expenditure capitalised on plant and machinery qualifies for depreciation at 15%, rejecting the CIT(A)'s contrary deletion.
The ITAT remitted and disposed issues as follows: directed recomputation of transfer-pricing interest on outstanding receivables at LIBOR + 0.65% (rejecting application of the Coordinate Bench's prior basis point and the CIT(A)'s LIBOR + 0.5%); deleted the TPO adjustment relating to interest on share-application monies where shares were allotted within six months; held that no disallowance under s.14A read with Rule 8D is sustainable because the assessee earned no exempt income and the 2022 amendment is prospective; and held that major overhauling expenditure capitalised on plant and machinery qualifies for depreciation at 15%, rejecting the CIT(A)'s contrary deletion.
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