Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Transfer pricing comparability adjustments were examined on foreign exchange fluctuation, customs duty, price penetration, liability write-back, and capacity utilisation. Consistent treatment of foreign exchange movement as non-operating in earlier and later years led to remand for fresh consideration. Customs duty and price penetration adjustment claims were also remitted because the factual basis and supporting details were not adequately examined. Liability write-back was treated as operating income where the underlying trade payables related to operating expenses, while other breakup items required verification. For capacity utilisation, the Tribunal rejected a depreciation-to-sales adjustment method as not reasonably accurate, but directed recomputation of ALP using cash PLI for the assessee and comparables.
Transfer pricing comparability adjustments were examined on foreign exchange fluctuation, customs duty, price penetration, liability write-back, and capacity utilisation. Consistent treatment of foreign exchange movement as non-operating in earlier and later years led to remand for fresh consideration. Customs duty and price penetration adjustment claims were also remitted because the factual basis and supporting details were not adequately examined. Liability write-back was treated as operating income where the underlying trade payables related to operating expenses, while other breakup items required verification. For capacity utilisation, the Tribunal rejected a depreciation-to-sales adjustment method as not reasonably accurate, but directed recomputation of ALP using cash PLI for the assessee and comparables.
Note: It is a system-generated summary and is for quick reference only.