Proportionate interest, unexplained credits and partner remuneration disputed; proofs of fund nexus and lender identity were decisive and disallowance...
Capital gains valuation from stamp assessment versus net consideration for residential reinvestment: deemed stamp value replaced for gains but not for...
Where a dependent agent permanent establishment in India has already been remunerated at arm's length, no further profits are attributable to that permanent establishment. Applying Morgan Stanley and Honda Motors, the ITAT held that the AO's ad hoc attribution of revenue and estimation of profit under Rule 10 was unjustified because the transfer pricing study had been furnished and the arm's length nature of the transactions was neither adversely examined nor doubted. The addition for further profit attribution was deleted, and the remaining grounds were treated as academic.
Where a dependent agent permanent establishment in India has already been remunerated at arm's length, no further profits are attributable to that permanent establishment. Applying Morgan Stanley and Honda Motors, the ITAT held that the AO's ad hoc attribution of revenue and estimation of profit under Rule 10 was unjustified because the transfer pricing study had been furnished and the arm's length nature of the transactions was neither adversely examined nor doubted. The addition for further profit attribution was deleted, and the remaining grounds were treated as academic.
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