Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
Benami property exclusion from the insolvency estate: Benami Act proceedings preclude IBC tribunals from reopening attachments or treating such assets...
Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
The principal issue was whether AMP expenditure forms part of operating costs for ALP determination in related-party transactions; holding that the TP study wrongly excluded AMP from operating cost, the tribunal remands the ALP determination to AO/TPO directing AMP be treated within operating cost and re-evaluated accordingly. On interest for delayed receivables the tribunal holds such interest is a separate international transaction requiring separate benchmarking; credit period limited to 30 days per contract and the benchmark rate directed as LIBOR + 200 bps (replacing LIBOR + 400 bps). Seminar/convention expenses must be verified against the Supreme Court test and, if compliant, allowed. Alleged double disallowance under s.43B is remitted to AO to delete if already disallowed in computation. - ITAT
The principal issue was whether AMP expenditure forms part of operating costs for ALP determination in related-party transactions; holding that the TP study wrongly excluded AMP from operating cost, the tribunal remands the ALP determination to AO/TPO directing AMP be treated within operating cost and re-evaluated accordingly. On interest for delayed receivables the tribunal holds such interest is a separate international transaction requiring separate benchmarking; credit period limited to 30 days per contract and the benchmark rate directed as LIBOR + 200 bps (replacing LIBOR + 400 bps). Seminar/convention expenses must be verified against the Supreme Court test and, if compliant, allowed. Alleged double disallowance under s.43B is remitted to AO to delete if already disallowed in computation. - ITAT
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