Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
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The Tribunal deleted the transfer pricing adjustment on corporate guarantee fee, holding that 0.25% was already accepted in the assessee's own earlier years and the higher rate was unsupported. It also deleted the adjustment on software cost allocation, rejecting re-characterisation of a cost-to-cost transaction as intra-group services. For electricity transfer pricing, it held that SEB rates were the proper benchmark and remanded the matter for verification and fresh determination. The duplicate disallowance under section 80-IA was held unsustainable, and the section 14A disallowance was deleted because no exempt income was earned. The section 115JB adjustment on education cess and interest under section 234A were both remanded for fresh verification.
The Tribunal deleted the transfer pricing adjustment on corporate guarantee fee, holding that 0.25% was already accepted in the assessee's own earlier years and the higher rate was unsupported. It also deleted the adjustment on software cost allocation, rejecting re-characterisation of a cost-to-cost transaction as intra-group services. For electricity transfer pricing, it held that SEB rates were the proper benchmark and remanded the matter for verification and fresh determination. The duplicate disallowance under section 80-IA was held unsustainable, and the section 14A disallowance was deleted because no exempt income was earned. The section 115JB adjustment on education cess and interest under section 234A were both remanded for fresh verification.
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