Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
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The ITAT set aside the impugned transfer-pricing adjustments and remitted issues to the AO/TPO for fresh determination. With respect to the ITES segment, the Tribunal directed a detailed FAR analysis of transactions with non-UK AEs to assess comparability with UK transactions resolved under the MAP; if comparable, the 18% operating-cost margin agreed by the Competent Authorities shall be applied. The manufacturing-segment comparables were also remitted for a fresh FAR and comparability analysis, with specific instruction to apply related-party, import/export and turnover filters under Rules 10B(2)-10B(3). The addition relating to management charges was dismissed as withdrawn. The assessee to be afforded opportunity of hearing and to furnish documentation.
The ITAT set aside the impugned transfer-pricing adjustments and remitted issues to the AO/TPO for fresh determination. With respect to the ITES segment, the Tribunal directed a detailed FAR analysis of transactions with non-UK AEs to assess comparability with UK transactions resolved under the MAP; if comparable, the 18% operating-cost margin agreed by the Competent Authorities shall be applied. The manufacturing-segment comparables were also remitted for a fresh FAR and comparability analysis, with specific instruction to apply related-party, import/export and turnover filters under Rules 10B(2)-10B(3). The addition relating to management charges was dismissed as withdrawn. The assessee to be afforded opportunity of hearing and to furnish documentation.
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