Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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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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