Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Extended period of limitation unsustainable; allowable deductions for prompt payment discounts, pro rata recovery, freight and VAT led to demand being...
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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