Reassessment under s.148A held valid; s.69 additions totaling Rs.7,00,000 deleted after acceptable contemporaneous explanations for property investmen...
Adjudication set aside; Rule 9 valuation based on internet engineer report quashed for Rule 3(4) non-compliance; Section 138B cross-examination requir...
ITAT upheld the appellate order, finding the taxpayer acted as agent of its principal (AE) and that 50% of documentation and telex charges were proper reimbursements credited in the books on a principal-and-agent basis rather than assessable international transactions for ALP adjustment. The Tribunal recorded that amounts received were held on behalf of the principal, corresponding expenses were not borne by the taxpayer, and the charge allocation corroborated by Form 3CEB supported agency treatment. Relying on authoritative SC precedent addressing like facts and absent contrary judicial authority or ALP adjustments in adjacent years, ITAT dismissed Revenue's grounds and affirmed there was no infirmity in the impugned appellate order.
ITAT upheld the appellate order, finding the taxpayer acted as agent of its principal (AE) and that 50% of documentation and telex charges were proper reimbursements credited in the books on a principal-and-agent basis rather than assessable international transactions for ALP adjustment. The Tribunal recorded that amounts received were held on behalf of the principal, corresponding expenses were not borne by the taxpayer, and the charge allocation corroborated by Form 3CEB supported agency treatment. Relying on authoritative SC precedent addressing like facts and absent contrary judicial authority or ALP adjustments in adjacent years, ITAT dismissed Revenue's grounds and affirmed there was no infirmity in the impugned appellate order.
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