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...
Transfer pricing controversy turned on the correct characterization of transactions between an LLP and its associated enterprise, the proper appreciation of their FAR profiles, and the resulting arm's length pricing analysis. The Tribunal noted that the revenue authorities had relied on assumptions about the entities' activities and risk allocation, while the assessee's claim of cost-to-cost reimbursement had not been tested against complete contemporaneous material, including financials, employee profile, contractual terms and risk assumption. It held that the basis for applying the Profit Split Method was insufficiently reasoned and required fresh examination. The assessment and DRP-backed adjustment were set aside and the matter was restored to the AO/TPO for de novo adjudication and a speaking order.
Transfer pricing controversy turned on the correct characterization of transactions between an LLP and its associated enterprise, the proper appreciation of their FAR profiles, and the resulting arm's length pricing analysis. The Tribunal noted that the revenue authorities had relied on assumptions about the entities' activities and risk allocation, while the assessee's claim of cost-to-cost reimbursement had not been tested against complete contemporaneous material, including financials, employee profile, contractual terms and risk assumption. It held that the basis for applying the Profit Split Method was insufficiently reasoned and required fresh examination. The assessment and DRP-backed adjustment were set aside and the matter was restored to the AO/TPO for de novo adjudication and a speaking order.
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