Condonation of Delay denied: communication lapses and corporate restructuring found insufficient; prolonged inaction and lack of bona fides led to ref...
Export Support intervention INSIGHT launched to provide non financial capacity building, trade intelligence and pilot support with defined funding and...
Transfer pricing assessment addressed comparability and benchmarking: TNMM comparables were adjusted where functional dissimilarity, related-party transactions filter and high outsourcing materially affected arm's length pricing, with a limited remand to verify exclusion of one comparable; five previously rejected comparables are to be included. Guarantee commission was benchmarked by CUP but accepted on an allocation reflecting the assessee's FAR and back-to-back risk allocation, deleting the upward adjustment. TDS liability under section 195/40(a)(i) judged by law at payment date; payments to foreign card networks were not taxable in India and disallowance deleted. Prior-year taxation settled under Vivad se Vishwas adjusted to avoid double taxation.
Transfer pricing assessment addressed comparability and benchmarking: TNMM comparables were adjusted where functional dissimilarity, related-party transactions filter and high outsourcing materially affected arm's length pricing, with a limited remand to verify exclusion of one comparable; five previously rejected comparables are to be included. Guarantee commission was benchmarked by CUP but accepted on an allocation reflecting the assessee's FAR and back-to-back risk allocation, deleting the upward adjustment. TDS liability under section 195/40(a)(i) judged by law at payment date; payments to foreign card networks were not taxable in India and disallowance deleted. Prior-year taxation settled under Vivad se Vishwas adjusted to avoid double taxation.
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