Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
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 4828 
Join Channel 
