Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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ITAT held: the challenge to the assessment under s.153 is kept open pending adjudication before the Hon'ble SC; AO directed to give effect to the SC outcome in the pending proceedings. Claim for deduction under s.80IA was remanded to the AO for factual verification under the second proviso to s.80IA(4) to determine whether the projects commenced development or O&M on/after 1.4.2017, precluding a conclusive appellate finding. On TP adjustments, ITAT found the specified domestic transactions benchmarked on CUP valid: where the AE passed government receipts to the assessee without mark-up under back-to-back contracts, those receipts constituted ALP; TPO's reallocation of corporate costs exceeded TP scope, so AO's TP additions were deleted.
ITAT held: the challenge to the assessment under s.153 is kept open pending adjudication before the Hon'ble SC; AO directed to give effect to the SC outcome in the pending proceedings. Claim for deduction under s.80IA was remanded to the AO for factual verification under the second proviso to s.80IA(4) to determine whether the projects commenced development or O&M on/after 1.4.2017, precluding a conclusive appellate finding. On TP adjustments, ITAT found the specified domestic transactions benchmarked on CUP valid: where the AE passed government receipts to the assessee without mark-up under back-to-back contracts, those receipts constituted ALP; TPO's reallocation of corporate costs exceeded TP scope, so AO's TP additions were deleted.
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