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...
The article addresses transfer pricing adjustments for NCDs, applying the comparability filter to exclude specified opening NCDs from ALP adjustment and directing that the NCD with 13.20% coupon be benchmarked afresh using the Internal Comparable Uncontrolled Price as the most appropriate method after the assessee had furnished a benchmarking submission. It also holds that an appellate authority may admit a fresh deduction claim for customer incentives and remits quantification to the assessing officer for de novo adjudication. The assessing officer is directed to grant statutory interest on any refund in accordance with law.
The article addresses transfer pricing adjustments for NCDs, applying the comparability filter to exclude specified opening NCDs from ALP adjustment and directing that the NCD with 13.20% coupon be benchmarked afresh using the Internal Comparable Uncontrolled Price as the most appropriate method after the assessee had furnished a benchmarking submission. It also holds that an appellate authority may admit a fresh deduction claim for customer incentives and remits quantification to the assessing officer for de novo adjudication. The assessing officer is directed to grant statutory interest on any refund in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
