Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
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 The addition relating to management charges was dismissed as withdrawn.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 The addition relating to management charges was dismissed as withdrawn.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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