Charitable registration renewal cannot become an assessment of receipts, profitability or annual exemption compliance, requiring renewal and donation ...
AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
Customs valuation must use comparable contemporary imports, while confiscation fines and penalties require proportionate recalculation on reassessed v...
Depositor-protection proceedings prevail over corporate insolvency, while liquidators may recover chit receivables using copies of seized company reco...
Transfer pricing adjustment on overdue receivables was upheld only in principle, but recomputation was ordered on the basis of a 90-day credit period, verification of comparable credit terms, correction of receipt dates, and fresh benchmarking of the arm's length interest rate through proper FAR analysis. The plea that no interest could be imputed to a debt-free entity was rejected, and the working capital adjustment argument failed because no such adjustment had been claimed in the transfer pricing study. The Tribunal also directed deletion of the double addition for foreign exchange loss, correction of the mismatch between assessed income and the computation sheet, and grant of TDS and foreign tax credit. Interest under section 234A was deleted because the return was filed within the extended due date.
Transfer pricing adjustment on overdue receivables was upheld only in principle, but recomputation was ordered on the basis of a 90-day credit period, verification of comparable credit terms, correction of receipt dates, and fresh benchmarking of the arm's length interest rate through proper FAR analysis. The plea that no interest could be imputed to a debt-free entity was rejected, and the working capital adjustment argument failed because no such adjustment had been claimed in the transfer pricing study. The Tribunal also directed deletion of the double addition for foreign exchange loss, correction of the mismatch between assessed income and the computation sheet, and grant of TDS and foreign tax credit. Interest under section 234A was deleted because the return was filed within the extended due date.
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