Penalty for estimation of income and disallowances for tax non-deduction clarified: estimation-based penalties not sustainable; additions without conc...
Managerial remuneration disallowance under s.40A(2)(b) challenged over alleged tax-avoidance; appellate decision restored deletion of addition for dir...
Classification of imported goods as electronic cigarette versus tobacco product reversed for lack of proof; order set aside for jurisdictional overrea...
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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