Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Business and management consultancy charges closely linked to the assessee's operations were held to be benchmarked on an aggregated basis under TNMM, not by a separate ALP analysis, where receipt of services was supported by additional evidence; the matter was remitted for fresh examination by the TPO after considering that evidence. For outstanding receivables from the associated enterprise, the Tribunal applied average LIBOR as the appropriate benchmark rate for delayed payment interest, rejecting the ad hoc higher rate adopted by the lower authorities. The appeal was partly allowed, with consultancy charges sent back for recomputation and receivable interest directed to be recalculated using average LIBOR.
Business and management consultancy charges closely linked to the assessee's operations were held to be benchmarked on an aggregated basis under TNMM, not by a separate ALP analysis, where receipt of services was supported by additional evidence; the matter was remitted for fresh examination by the TPO after considering that evidence. For outstanding receivables from the associated enterprise, the Tribunal applied average LIBOR as the appropriate benchmark rate for delayed payment interest, rejecting the ad hoc higher rate adopted by the lower authorities. The appeal was partly allowed, with consultancy charges sent back for recomputation and receivable interest directed to be recalculated using average LIBOR.
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