Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
ITAT held that back-to-back guarantee processing fees were correctly benchmarked under TNMM, because the assessee acted only as an administrative intermediary and did not bear the invocation risk; bank guarantee rates from third parties were not comparable, so the transfer-pricing adjustment was deleted. For derivative-related marketing support services, the Tribunal rejected PSM based on day-end NPV because the transactions were back-to-back, the assessee bore no trading risk, and aggregation of closely linked transactions left no surviving adjustment. It also held that telecommunication and expatriate personnel costs incurred exclusively for the Indian branch were direct branch expenses, not common administrative , so section 44C disallowance failed. Interest paid by the branch to head office or overseas branches remained a payment to self and was not taxable for the year in issue.
ITAT held that back-to-back guarantee processing fees were correctly benchmarked under TNMM, because the assessee acted only as an administrative intermediary and did not bear the invocation risk; bank guarantee rates from third parties were not comparable, so the transfer-pricing adjustment was deleted. For derivative-related marketing support services, the Tribunal rejected PSM based on day-end NPV because the transactions were back-to-back, the assessee bore no trading risk, and aggregation of closely linked transactions left no surviving adjustment. It also held that telecommunication and expatriate personnel costs incurred exclusively for the Indian branch were direct branch expenses, not common administrative , so section 44C disallowance failed. Interest paid by the branch to head office or overseas branches remained a payment to self and was not taxable for the year in issue.
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