Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
Administrative fraud classification suspension does not halt independent criminal investigation or warrant-based searches into alleged economic offenc...
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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