Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
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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