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...
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In transfer pricing, broad functional comparability under TNMM was applied: Bright Brothers Ltd. was retained because product differences did not matter where functions were broadly similar, and REIL Electricals India Ltd. was included as functionally similar. Working capital adjustment was treated as a valid claim and was directed to be allowed, subject to the assessee furnishing supporting details and data. On royalty, technical know-how and technical services, the Tribunal upheld deletion of the adjustment because CUP was adopted without comparable uncontrolled data and the principle of consistency supported the assessee, as no adjustment had been made in earlier or subsequent years on the same agreements.
In transfer pricing, broad functional comparability under TNMM was applied: Bright Brothers Ltd. was retained because product differences did not matter where functions were broadly similar, and REIL Electricals India Ltd. was included as functionally similar. Working capital adjustment was treated as a valid claim and was directed to be allowed, subject to the assessee furnishing supporting details and data. On royalty, technical know-how and technical services, the Tribunal upheld deletion of the adjustment because CUP was adopted without comparable uncontrolled data and the principle of consistency supported the assessee, as no adjustment had been made in earlier or subsequent years on the same agreements.
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