Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Objective characteristics govern magnesium bis-glycinate chelate classification as an amino-acid coordination compound, not a food preparation or anti...
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In a transfer pricing dispute over specified domestic transactions for purchase of potatoes from an associated enterprise, the Tribunal held that the earlier coordinate bench ruling in the assessee's own case for the preceding year governed the issue on identical facts. Applying judicial discipline, it rejected the DRP's attempt to keep the matter open for the Revenue and found that CUP was not the most appropriate method. TNMM was upheld as the appropriate arm's length method, so the transfer pricing adjustment based on CUP was deleted. As the substantive addition did not survive, the consequential penalty proceedings for alleged under-reporting or misreporting under section 270A were rendered infructuous.
In a transfer pricing dispute over specified domestic transactions for purchase of potatoes from an associated enterprise, the Tribunal held that the earlier coordinate bench ruling in the assessee's own case for the preceding year governed the issue on identical facts. Applying judicial discipline, it rejected the DRP's attempt to keep the matter open for the Revenue and found that CUP was not the most appropriate method. TNMM was upheld as the appropriate arm's length method, so the transfer pricing adjustment based on CUP was deleted. As the substantive addition did not survive, the consequential penalty proceedings for alleged under-reporting or misreporting under section 270A were rendered infructuous.
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