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...
ITAT remanded the transfer-pricing issues to the file of the AO/TPO for fresh benchmarking of international transactions, holding that key contentions raised by the assessee regarding pricing and comparability were raised for the first time on appeal and require reconsideration; grounds 2-8 were partly allowed for statistical purposes. The Tribunal directed the AO/TPO to permit interest disallowance under the proviso to s.36(1) to be treated as revenue expenditure in favour of the assessee. The Tribunal also held that contested advertisement expenditure is revenue in nature and allowed the corresponding ground of appeal.
ITAT remanded the transfer-pricing issues to the file of the AO/TPO for fresh benchmarking of international transactions, holding that key contentions raised by the assessee regarding pricing and comparability were raised for the first time on appeal and require reconsideration; grounds 2-8 were partly allowed for statistical purposes. The Tribunal directed the AO/TPO to permit interest disallowance under the proviso to s.36(1) to be treated as revenue expenditure in favour of the assessee. The Tribunal also held that contested advertisement expenditure is revenue in nature and allowed the corresponding ground of appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
