Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
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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