Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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