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...
Transfer pricing adjustment challenged the use of differential commission rates by revenue authorities; the TPO/AO applied an ad hoc thumb rule without evidentiary comparables. Treating commission received as the arm's length price for benchmarking commission paid was held impermissible where transactions were not between uncontrolled parties or concluded on uncontrolled conditions. Consequently, the impugned addition was deleted. The AO is directed to give effect to this order and reassess and charge interest consequentially under the relevant tax provisions, and to verify the filing due date before considering interest under the return filing provision.
Transfer pricing adjustment challenged the use of differential commission rates by revenue authorities; the TPO/AO applied an ad hoc thumb rule without evidentiary comparables. Treating commission received as the arm's length price for benchmarking commission paid was held impermissible where transactions were not between uncontrolled parties or concluded on uncontrolled conditions. Consequently, the impugned addition was deleted. The AO is directed to give effect to this order and reassess and charge interest consequentially under the relevant tax provisions, and to verify the filing due date before considering interest under the return filing provision.
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