Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Transfer pricing adjustment was confined to international transactions with the associated enterprise, consistent with the settled view that arm's length pricing under transfer pricing provisions cannot be extended to the assessee's entire when the dispute concerns only controlled transactions. The Tribunal also sustained directions on capacity utilisation and working capital adjustments, noting that both claims had been verified and allowed on facts, leaving no surviving grievance for interference. It further upheld uniform operating treatment of forex gain and provision write-back for transfer pricing purposes, finding no basis to depart from consistency. The Revenue's challenges on all these issues were dismissed.
Transfer pricing adjustment was confined to international transactions with the associated enterprise, consistent with the settled view that arm's length pricing under transfer pricing provisions cannot be extended to the assessee's entire when the dispute concerns only controlled transactions. The Tribunal also sustained directions on capacity utilisation and working capital adjustments, noting that both claims had been verified and allowed on facts, leaving no surviving grievance for interference. It further upheld uniform operating treatment of forex gain and provision write-back for transfer pricing purposes, finding no basis to depart from consistency. The Revenue's challenges on all these issues were dismissed.
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