Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Transfer pricing adjustment under s.92 required correct segmentation where the tax authority had aggregated marketing support/indenting and spare parts trading (AMC) as a single segment. The Tribunal held benchmarking must be performed separately for the two segments as presented by the taxpayer; the TPO must re-examine comparables and verify whether the taxpayer's results fall within the tolerance range under the proviso to s.92C(2), and the ALP determination was remanded. On non-compete fee, in light of the latest binding precedent, it was held to be revenue in nature; the AO was directed to treat it accordingly and to recompute consequential depreciation impact already claimed with the taxpayer's assistance - ITAT
Transfer pricing adjustment under s.92 required correct segmentation where the tax authority had aggregated marketing support/indenting and spare parts trading (AMC) as a single segment. The Tribunal held benchmarking must be performed separately for the two segments as presented by the taxpayer; the TPO must re-examine comparables and verify whether the taxpayer's results fall within the tolerance range under the proviso to s.92C(2), and the ALP determination was remanded. On non-compete fee, in light of the latest binding precedent, it was held to be revenue in nature; the AO was directed to treat it accordingly and to recompute consequential depreciation impact already claimed with the taxpayer's assistance - ITAT
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