Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
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...
ITAT held that the TPO's ad-hoc 50% adjustment to RHQ charges lacked a suitable comparable and did not comply with Rule 10AB or section 92C, rendering the benchmarking unsustainable; the TPO failed to apply any prescribed method or to bring a comparable uncontrolled price on record when invoking the "Other Method," and therefore the ALP determination was void. On the facts and law the Tribunal accepted the Taxpayer's aggregation/TNMM as the Most Appropriate Method and directed deletion of the entire transfer-pricing adjustment relating to allocation of RHQ charges, noting the AO/TPO's non-compliance with statutory provisions and absence of rebuttal material from the Revenue.
ITAT held that the TPO's ad-hoc 50% adjustment to RHQ charges lacked a suitable comparable and did not comply with Rule 10AB or section 92C, rendering the benchmarking unsustainable; the TPO failed to apply any prescribed method or to bring a comparable uncontrolled price on record when invoking the "Other Method," and therefore the ALP determination was void. On the facts and law the Tribunal accepted the Taxpayer's aggregation/TNMM as the Most Appropriate Method and directed deletion of the entire transfer-pricing adjustment relating to allocation of RHQ charges, noting the AO/TPO's non-compliance with statutory provisions and absence of rebuttal material from the Revenue.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
