Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Under the faceless assessment framework, specialized units (Assessment, Verification, Technical, Review) must conduct or procure factual verification when complex technical claims arise. The Principal Commissioner found the assessment silent on actuarial valuation of post employment benefit remeasurement, payments vis a vis tax deductibility rules, and adjustments for realized foreign exchange gains to capital assets, with no Verification Unit report or recorded enquiries. That absence amounted to a lack of enquiry rather than mere inadequate enquiry; consequence: the assessment was set aside and the Assessing Officer directed to carry out proper verification and pass a fresh order after allowing the taxpayer opportunity to be heard.
Under the faceless assessment framework, specialized units (Assessment, Verification, Technical, Review) must conduct or procure factual verification when complex technical claims arise. The Principal Commissioner found the assessment silent on actuarial valuation of post employment benefit remeasurement, payments vis a vis tax deductibility rules, and adjustments for realized foreign exchange gains to capital assets, with no Verification Unit report or recorded enquiries. That absence amounted to a lack of enquiry rather than mere inadequate enquiry; consequence: the assessment was set aside and the Assessing Officer directed to carry out proper verification and pass a fresh order after allowing the taxpayer opportunity to be heard.
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