Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Where TNMM had been accepted as the most appropriate method, the net margin was held to subsume the effect of notional interest on outstanding receivables, so no separate upward adjustment was warranted and the receivables adjustment was deleted. The arm's length rate on ECB interest was upheld at LIBOR plus 200 basis points, following the assessee's earlier years, so that adjustment was sustained. Leasehold charges were treated as proportionately amortisable over the lease term, and the disallowance of the year's claim was vacated. Royalty was held not to permit separate benchmarking once aggregated under TNMM, but the issue was remitted because the operating cost used for PLI computation did not reconcile with the books.
Where TNMM had been accepted as the most appropriate method, the net margin was held to subsume the effect of notional interest on outstanding receivables, so no separate upward adjustment was warranted and the receivables adjustment was deleted. The arm's length rate on ECB interest was upheld at LIBOR plus 200 basis points, following the assessee's earlier years, so that adjustment was sustained. Leasehold charges were treated as proportionately amortisable over the lease term, and the disallowance of the year's claim was vacated. Royalty was held not to permit separate benchmarking once aggregated under TNMM, but the issue was remitted because the operating cost used for PLI computation did not reconcile with the books.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4826 
Join Channel 
