Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Transfer pricing disputes concerned reimbursements of personnel cost, IT-related expenses, advertisement and publicity expenses, and royalty. The Tribunal upheld deletion of adjustments on personnel cost and IT-related reimbursements because the assessee showed they were pure cost-to-cost items, with supporting material and no markup; the personnel-cost issue was also covered by the assessee's earlier years' orders. The Tribunal sustained the adjustment on advertisement and publicity reimbursement because the assessee failed to produce documentary evidence establishing the need for and incurrence of the . The royalty adjustment was deleted on consistency, the issue being covered by the assessee's own earlier order.
Transfer pricing disputes concerned reimbursements of personnel cost, IT-related expenses, advertisement and publicity expenses, and royalty. The Tribunal upheld deletion of adjustments on personnel cost and IT-related reimbursements because the assessee showed they were pure cost-to-cost items, with supporting material and no markup; the personnel-cost issue was also covered by the assessee's earlier years' orders. The Tribunal sustained the adjustment on advertisement and publicity reimbursement because the assessee failed to produce documentary evidence establishing the need for and incurrence of the . The royalty adjustment was deleted on consistency, the issue being covered by the assessee's own earlier order.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
