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Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Business expenditure claims for shortages and quality cuts were sent back for fresh verification because the lower authorities had rejected them for want of complete supporting evidence, while the Tribunal found no corroboration for the assumption that the goods remained in closing stock and noted that additional material had not yet been examined. The transfer pricing adjustment under the CUP method was also remanded because a disputed credit note appeared to involve only a clerical date error, and the revised arm's length computation with discounts and credit notes required verification. The omitted TDS credit was ordered to be granted because it had been acknowledged in the draft computation and was not denied by any DRP direction.
Business expenditure claims for shortages and quality cuts were sent back for fresh verification because the lower authorities had rejected them for want of complete supporting evidence, while the Tribunal found no corroboration for the assumption that the goods remained in closing stock and noted that additional material had not yet been examined. The transfer pricing adjustment under the CUP method was also remanded because a disputed credit note appeared to involve only a clerical date error, and the revised arm's length computation with discounts and credit notes required verification. The omitted TDS credit was ordered to be granted because it had been acknowledged in the draft computation and was not denied by any DRP direction.
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