Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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ITAT remanded certain TP issues to the AO/TPO: additional evidence submitted by the assessee must be verified and the TPO shall determine benefit and compute ALP adopting TNMM in accordance with s.92C and Rules 10B/10C, affording the assessee hearing. The TPO exceeded jurisdiction by itemising assets in a slump sale and applying s.50C; the Tribunal directed acceptance of DCF valuation and the Form 3CEA fair value under s.50B. Selection of specified comparables for IPS division was upheld. Reimbursements by the assessee to its AE are cost-to-cost with no separate mark-up. Disallowance of provisions for contract losses was sustained; reversal is partly allowed subject to AO's verification of creation year and linkage to the disallowed provision.
ITAT remanded certain TP issues to the AO/TPO: additional evidence submitted by the assessee must be verified and the TPO shall determine benefit and compute ALP adopting TNMM in accordance with s.92C and Rules 10B/10C, affording the assessee hearing. The TPO exceeded jurisdiction by itemising assets in a slump sale and applying s.50C; the Tribunal directed acceptance of DCF valuation and the Form 3CEA fair value under s.50B. Selection of specified comparables for IPS division was upheld. Reimbursements by the assessee to its AE are cost-to-cost with no separate mark-up. Disallowance of provisions for contract losses was sustained; reversal is partly allowed subject to AO's verification of creation year and linkage to the disallowed provision.
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