Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Transfer pricing adjustment arising from royalty payments requires benchmarking by the most appropriate traditional transaction method; where exact identical comparables exist the CUP method should be applied, but selected comparables must be functionally comparable and not mere local manufacturers or brand developers. The impugned comparables were held inappropriate and the matter is remitted to AO/TPO to re-benchmark afresh after affording the assessee hearing and considering the submitted TPAR; if no exact comparables receiving bundled services are found, benchmarking should proceed under TNMM using proper comparables.
Transfer pricing adjustment arising from royalty payments requires benchmarking by the most appropriate traditional transaction method; where exact identical comparables exist the CUP method should be applied, but selected comparables must be functionally comparable and not mere local manufacturers or brand developers. The impugned comparables were held inappropriate and the matter is remitted to AO/TPO to re-benchmark afresh after affording the assessee hearing and considering the submitted TPAR; if no exact comparables receiving bundled services are found, benchmarking should proceed under TNMM using proper comparables.
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