Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
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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