Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
The ITAT held that once TNMM benchmarking of logistics services had been accepted on a combined basis, the same cost elements could not be separately benchmarked again for royalty and GAM charges, so those additional transfer pricing adjustments were deleted. It restored the working capital adjustment to the AO/TPO for fresh consideration on the basis of the material already furnished. On CSR-related donations, the Tribunal held that disallowance under Explanation 2 to section 37(1) does not bar deduction under section 80G where the donation otherwise qualifies, and allowed the claim. TDS/TCS credit and the section 43B issue were remanded for verification and fresh decision.
The ITAT held that once TNMM benchmarking of logistics services had been accepted on a combined basis, the same cost elements could not be separately benchmarked again for royalty and GAM charges, so those additional transfer pricing adjustments were deleted. It restored the working capital adjustment to the AO/TPO for fresh consideration on the basis of the material already furnished. On CSR-related donations, the Tribunal held that disallowance under Explanation 2 to section 37(1) does not bar deduction under section 80G where the donation otherwise qualifies, and allowed the claim. TDS/TCS credit and the section 43B issue were remanded for verification and fresh decision.
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