Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
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The ITAT directed the AO/TPO to delete the addition for corporate guarantee commission assessed at 0.5% and sustained the assessee's appeal. The Tribunal rejected the protective adjustment of 0.5% as a risk-mitigation factor, holding that the assessee's advance to its associated enterprise (AE) carrying interest at 1.9%-matching the bank's rate-was consistent with arm's-length principles. The ITAT found the AO/TPO's determination of ALP flawed for failing to apply any prescribed method under s.92C and for not undertaking a benchmarking exercise or valuing the specific services received from the AE; consequently the impugned transfer pricing adjustments were set aside and the appeal allowed.
The ITAT directed the AO/TPO to delete the addition for corporate guarantee commission assessed at 0.5% and sustained the assessee's appeal. The Tribunal rejected the protective adjustment of 0.5% as a risk-mitigation factor, holding that the assessee's advance to its associated enterprise (AE) carrying interest at 1.9%-matching the bank's rate-was consistent with arm's-length principles. The ITAT found the AO/TPO's determination of ALP flawed for failing to apply any prescribed method under s.92C and for not undertaking a benchmarking exercise or valuing the specific services received from the AE; consequently the impugned transfer pricing adjustments were set aside and the appeal allowed.
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