Composite supply of drilling services and site specific chemicals characterised as composite supply; prior advance rulings set aside, tax rate left op...
Cross country pipeline classification and ITC entitlement: pipelines outside factory treated as immovable, ITC disallowed under Section 17 restriction...
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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