Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
TNMM was accepted for intra-group management fees and technology and trademark licence fees because the same transactions had been treated as interlinked in earlier and subsequent years, with no change in functions, assets or risks shown and evidence of services and business benefit on record; the CUP-based nil valuation was therefore unsustainable and the transfer pricing adjustments were deleted. SAP implementation cost was also treated as a reasonable, scientific allocation for IT support services because the services were used daily, billed by actual user headcount, and the need and rendition tests were satisfied; the nil ALP adjustment was deleted. The disallowance of employees' contribution to Provident Fund and ESIC was sustained under the Supreme Court ruling in Checkmate Service Private Limited.
TNMM was accepted for intra-group management fees and technology and trademark licence fees because the same transactions had been treated as interlinked in earlier and subsequent years, with no change in functions, assets or risks shown and evidence of services and business benefit on record; the CUP-based nil valuation was therefore unsustainable and the transfer pricing adjustments were deleted. SAP implementation cost was also treated as a reasonable, scientific allocation for IT support services because the services were used daily, billed by actual user headcount, and the need and rendition tests were satisfied; the nil ALP adjustment was deleted. The disallowance of employees' contribution to Provident Fund and ESIC was sustained under the Supreme Court ruling in Checkmate Service Private Limited.
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