Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
The Tribunal held that the interest on overdue receivables from associated enterprises could not be benchmarked at LIBOR plus 450 basis points because no justification was given for that rate, and directed recomputation at LIBOR plus 200 basis points. The ESOP-cost dispute was treated as infructuous since no transfer pricing adjustment survived in the ITeS segment. On CSR donations, it held that contributions made to trusts eligible under section 80G were not barred merely because they formed part of CSR expenditure, and directed allowance of the deduction where the assessee had not claimed section 37 relief. Interest under sections 234A and 234C was left to be recomputed in accordance with law.
The Tribunal held that the interest on overdue receivables from associated enterprises could not be benchmarked at LIBOR plus 450 basis points because no justification was given for that rate, and directed recomputation at LIBOR plus 200 basis points. The ESOP-cost dispute was treated as infructuous since no transfer pricing adjustment survived in the ITeS segment. On CSR donations, it held that contributions made to trusts eligible under section 80G were not barred merely because they formed part of CSR expenditure, and directed allowance of the deduction where the assessee had not claimed section 37 relief. Interest under sections 234A and 234C was left to be recomputed in accordance with law.
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