Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Disallowance of payments for intra-group services to an associated enterprise was examined on whether services were actually rendered and whether they were duplicative, stewardship, incidental, or on-call. Based on the nature and scale of operations, centralized group support, and audited accounts showing no double-claim of expenses, the tribunal held that the services were received and the expenditure was incurred; however, since the TPO had not examined the assessee's ALP under the prescribed approach despite TNMM being adopted, ALP determination was remanded to the TPO and the related grounds were allowed for statistical purposes. The challenge to the DRP/TPO's use of "other method" without comparables was rejected as meritless and dismissed. - ITAT
Disallowance of payments for intra-group services to an associated enterprise was examined on whether services were actually rendered and whether they were duplicative, stewardship, incidental, or on-call. Based on the nature and scale of operations, centralized group support, and audited accounts showing no double-claim of expenses, the tribunal held that the services were received and the expenditure was incurred; however, since the TPO had not examined the assessee's ALP under the prescribed approach despite TNMM being adopted, ALP determination was remanded to the TPO and the related grounds were allowed for statistical purposes. The challenge to the DRP/TPO's use of "other method" without comparables was rejected as meritless and dismissed. - ITAT
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TaxTMI 
TaxTMI 
of 4918 
