Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
ITAT allowed the appeal and set aside the orders of the lower authorities, directing the AO to delete the impugned addition arising from a downward TP adjustment in respect of global account management charges (GAM). The Tribunal held that the appellant reasonably quantified benefit from services rendered by its associated enterprise and that aggregation and application of TNMM to the GAM charges was appropriate; the TPO erred in excluding GAM for separate benchmarking. On the facts, the GAM payments were inextricably linked to the appellant's core business and could not be segregated for independent benchmarking, resulting in a decision in favour of the appellant.
ITAT allowed the appeal and set aside the orders of the lower authorities, directing the AO to delete the impugned addition arising from a downward TP adjustment in respect of global account management charges (GAM). The Tribunal held that the appellant reasonably quantified benefit from services rendered by its associated enterprise and that aggregation and application of TNMM to the GAM charges was appropriate; the TPO erred in excluding GAM for separate benchmarking. On the facts, the GAM payments were inextricably linked to the appellant's core business and could not be segregated for independent benchmarking, resulting in a decision in favour of the appellant.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
