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...
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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