Fair-rent assessment requires consideration of lease terms, valuation principles and prevailing market rent; the certificate was quashed for fresh rev...
Document Identification Number compliance is satisfied when electronically communicated orders are promptly authenticated through a correctly identifi...
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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