Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
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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