Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
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A second final assessment order for the same assessment year was held impermissible because a final order had already been passed pursuant to DRP directions; the later order was quashed as a duplicate assessment. Transfer pricing issues on intra-group services and royalty benchmarking were not finally decided and were remitted to the TPO for fresh adjudication and computation in line with earlier-year directions. Support service expenditure was held allowable on consistency with prior years, and the disallowance was deleted. Amortization of telecom licence fee and the related interest claim were sent back for consequential action in accordance with law. Deduction under section 80G for CSR expenditure, refund of excess dividend distribution tax at treaty rate, and road tax and VAT on leased assets were all allowed.
A second final assessment order for the same assessment year was held impermissible because a final order had already been passed pursuant to DRP directions; the later order was quashed as a duplicate assessment. Transfer pricing issues on intra-group services and royalty benchmarking were not finally decided and were remitted to the TPO for fresh adjudication and computation in line with earlier-year directions. Support service expenditure was held allowable on consistency with prior years, and the disallowance was deleted. Amortization of telecom licence fee and the related interest claim were sent back for consequential action in accordance with law. Deduction under section 80G for CSR expenditure, refund of excess dividend distribution tax at treaty rate, and road tax and VAT on leased assets were all allowed.
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