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 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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