Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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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