Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
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
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
