Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
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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