Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
ITAT upheld deletion of transfer-pricing adjustment on corporate guarantee, holding that no fresh guarantee was issued and no additional cost or economic outflow arose, so no arm's length commission could be imputed. It also sustained deletion of interest disallowance on borrowed funds, finding commercial expediency and no direct nexus with diversion. Weighted deduction under section 35(2AB) was largely allowed on the pre-amendment position, product registration expenditure was treated as revenue, and section 14A/MAT additions were restricted to actual exempt-income related expenditure. Foreign exchange derivative loss was accepted as business loss, while disallowance for freebies to doctors and delayed employees' contribution was upheld. The bonus deduction claim under section 43B was remanded for verification.
ITAT upheld deletion of transfer-pricing adjustment on corporate guarantee, holding that no fresh guarantee was issued and no additional cost or economic outflow arose, so no arm's length commission could be imputed. It also sustained deletion of interest disallowance on borrowed funds, finding commercial expediency and no direct nexus with diversion. Weighted deduction under section 35(2AB) was largely allowed on the pre-amendment position, product registration expenditure was treated as revenue, and section 14A/MAT additions were restricted to actual exempt-income related expenditure. Foreign exchange derivative loss was accepted as business loss, while disallowance for freebies to doctors and delayed employees' contribution was upheld. The bonus deduction claim under section 43B was remanded for verification.
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