Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
Reimbursements paid by the assessee to third-party vendors for marketing events organized for its AE, and recovered on a cost-to-cost basis, were held not to constitute an international transaction involving services, as the assessee merely facilitated payments without value addition; consequently, no separate mark-up could be imputed and the TP adjustment was deleted. Year-end provisions for installation/authorised services and sales commission were held allowable if not ad hoc and reversed in the immediately succeeding year; the installation/authorised services provision was remanded for AO verification of a scientific basis and, if proved, to be allowed. Book profits under section 115JB and interest were directed to be recomputed/verified as per law. - ITAT
Reimbursements paid by the assessee to third-party vendors for marketing events organized for its AE, and recovered on a cost-to-cost basis, were held not to constitute an international transaction involving services, as the assessee merely facilitated payments without value addition; consequently, no separate mark-up could be imputed and the TP adjustment was deleted. Year-end provisions for installation/authorised services and sales commission were held allowable if not ad hoc and reversed in the immediately succeeding year; the installation/authorised services provision was remanded for AO verification of a scientific basis and, if proved, to be allowed. Book profits under section 115JB and interest were directed to be recomputed/verified as per law. - ITAT
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