Transition support services from corporate spinoff for India business segment - TP adjustment deleted; comparables reassessed; goodwill depreciation, ...
Qualification of fire extinguishers as aircraft parts - original duty finding under Notification No.50/2017-Sr.545 vacated; remanded for fresh adjudic...
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
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4813 
Join Channel 
