Registration under s.12AB upheld; CIT(Exemptions) exceeded jurisdiction by deciding taxability instead of preliminary verification and registration di...
Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s deletions. The Tribunal affirmed the CIT(A)'s acceptance of the assessee's use of TNMM as the most appropriate MAM for benchmarking exports to AEs, noting consistency with prior appellate orders and inability of the Departmental Representative to show infirmity. The CIT(A)'s deletion of additions under s.40(a)(ia) for alleged TDS defaults was sustained on evidence of reversal of year-end provisions and subsequent booking of expenses. Deletions relating to ICDS adjustments, reversal of liquidated damages, project provisions and doubtful debts were likewise upheld on factual findings and documentary disclosures which the Revenue failed to controvert.
ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s deletions. The Tribunal affirmed the CIT(A)'s acceptance of the assessee's use of TNMM as the most appropriate MAM for benchmarking exports to AEs, noting consistency with prior appellate orders and inability of the Departmental Representative to show infirmity. The CIT(A)'s deletion of additions under s.40(a)(ia) for alleged TDS defaults was sustained on evidence of reversal of year-end provisions and subsequent booking of expenses. Deletions relating to ICDS adjustments, reversal of liquidated damages, project provisions and doubtful debts were likewise upheld on factual findings and documentary disclosures which the Revenue failed to controvert.
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