Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
ITAT held that remeasurement gain on defined employee benefit plans is an operating item for TNMM because it stems from the employer-employee cost structure and not from financing or investment activity, and the AO/TPO had to recompute the PLI accordingly. In selecting comparables, the Tribunal upheld inclusion or exclusion based on functional similarity, segmental data and RPT filters, while persistent loss treatment was accepted where applied consistently. It further held that transfer pricing adjustment must be restricted to international transactions with AEs, not domestic non-AE turnover. Interest on overdue receivables was to be benchmarked separately at LIBOR plus 200 basis points after a 30-day credit period, nil ALP for intra-group service charges was deleted, and credit for advance tax and TDS was remanded for verification.
ITAT held that remeasurement gain on defined employee benefit plans is an operating item for TNMM because it stems from the employer-employee cost structure and not from financing or investment activity, and the AO/TPO had to recompute the PLI accordingly. In selecting comparables, the Tribunal upheld inclusion or exclusion based on functional similarity, segmental data and RPT filters, while persistent loss treatment was accepted where applied consistently. It further held that transfer pricing adjustment must be restricted to international transactions with AEs, not domestic non-AE turnover. Interest on overdue receivables was to be benchmarked separately at LIBOR plus 200 basis points after a 30-day credit period, nil ALP for intra-group service charges was deleted, and credit for advance tax and TDS was remanded for verification.
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