Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
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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