Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
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Transfer pricing dispute over intra group management fees turned on whether payments were incurred for business purposes and whether services were actually rendered; AO found no services and set ALP at nil, and the tribunal noted that TPOs may compute NIL ALP after applying benefit, need and rendition tests, but remanded the matter to AO/TPO for fresh adjudication with opportunity to the assessee and to admit further evidence - grounds 2-12 allowed for statistical purposes. Separate addition for alleged set off of interest against electricity expenses was remanded for factual verification and reconciliation by the AO.
Transfer pricing dispute over intra group management fees turned on whether payments were incurred for business purposes and whether services were actually rendered; AO found no services and set ALP at nil, and the tribunal noted that TPOs may compute NIL ALP after applying benefit, need and rendition tests, but remanded the matter to AO/TPO for fresh adjudication with opportunity to the assessee and to admit further evidence - grounds 2-12 allowed for statistical purposes. Separate addition for alleged set off of interest against electricity expenses was remanded for factual verification and reconciliation by the AO.
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