Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Development rights transfers treated as immovable property, while construction abatement applies and repeated non-payment permits extended service-tax...
Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
The ITAT set aside the transfer pricing addition and related disallowance under s.37, rejecting the Revenue's determination of NIL ALP for intra-group services. The Tribunal overturned the TPO/DRP finding that the Taxpayer failed the need, purpose, rendition and benefit tests, held the Taxpayer's corroborative benchmarking (TNMM with the Indian entity as tested party and operating profit/sales as PLI) to be admissible, and directed the TPO to compute the ALP in accordance with that corroborative benchmarking after verifying the PLI computation. The ITAT declined the Revenue's submission equating the TPO approach to the "Other Method" and dismissed the AO/DRP directions disallowing the payments.
The ITAT set aside the transfer pricing addition and related disallowance under s.37, rejecting the Revenue's determination of NIL ALP for intra-group services. The Tribunal overturned the TPO/DRP finding that the Taxpayer failed the need, purpose, rendition and benefit tests, held the Taxpayer's corroborative benchmarking (TNMM with the Indian entity as tested party and operating profit/sales as PLI) to be admissible, and directed the TPO to compute the ALP in accordance with that corroborative benchmarking after verifying the PLI computation. The ITAT declined the Revenue's submission equating the TPO approach to the "Other Method" and dismissed the AO/DRP directions disallowing the payments.
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