Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
The Tribunal held that comparables lacking functional similarity were to be excluded, while Keystone Integrated Marketing Services Pvt. Ltd. had to be included because the DRP had already directed its inclusion. Pass-through third-party costs in the contract R&D segment, incurred without value addition and recovered on a cost-to-cost basis, were excluded from the PLI computation and the related transfer pricing addition was deleted. Working capital adjustment was recognised as an accepted TP adjustment and directed to be verified on actuals. The DRP's direction to set off contract R&D income against royalty attribution was binding on the AO, so the adjustment was reduced accordingly. Arithmetical errors and foreign tax credit claims were remanded for verification and recomputation.
The Tribunal held that comparables lacking functional similarity were to be excluded, while Keystone Integrated Marketing Services Pvt. Ltd. had to be included because the DRP had already directed its inclusion. Pass-through third-party costs in the contract R&D segment, incurred without value addition and recovered on a cost-to-cost basis, were excluded from the PLI computation and the related transfer pricing addition was deleted. Working capital adjustment was recognised as an accepted TP adjustment and directed to be verified on actuals. The DRP's direction to set off contract R&D income against royalty attribution was binding on the AO, so the adjustment was reduced accordingly. Arithmetical errors and foreign tax credit claims were remanded for verification and recomputation.
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