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TP - Market value of power supplied by CPP to industrial unit shall be computed by considering rate at which State Electricity Board supplied pow...
I-T - If AO has applied his discretion and reached plausible conclusion based on material on record, then revisionary authority cannot invoke sec...
I-T - Provisions of DTAA would override provisions of Domestic Act if provisions of DTAA are more beneficial to assessee: HC...
INTL - Where declared consideration was higher than stamp duty value on date of agreement, then benefit of the proviso to section 56(2)(vii)(b) w...
TP - AO cannot act beyond mandate of Section 144C(13) and also contrary to directions given by DRP u/s 144C(5): HC...
DTAA -LTCG from grandfathered sales & long-term capital loss from non-grandfathered sales, constitute distinct transactions & separate sources of...
TP - For purposes of determination of market value of transfer of electricity from eligible unit to non-eligible unit is to be taken at market va...
DTAA - Maintenance support services, education & training services, being intrinsically linked to software sold by assessee, the income therefrom...
TP - If cost allocation Key on 'headcount basis' was duly examined and accepted by TPO to be at ALP in transfer pricing proceedings u/s 92CA(3), ...
I-T - Condonation of delay should not be used as anticipated benefit for government departments and unless department has reasonable and acceptab...
I-T - Merely having Indian address is not sufficient to demonstrate business connection through which activities have been carried on in India an...
TP - CUP method can be applied in respect of such transactions only, where products of similar nature have been sold to unrelated parties, within...
TP - If NIC Codes, functional filter, and profit margin of two companies are different, then they cannot be taken as comparables for purpose of c...
I-T - Receipts earned by way of subscription towards provision of software-based information security solutions are business profits, not chargea...
TP - Captive service provider rendering services on cost-plus basis to its AE, can be compared to multi dimensional entity having huge brand valu...
TP - Existence of 'arrangement' is condition precedent to trigger Sec 80IA(10) and in its absence, business transacted between eligible units and...
TP - Mere assertion of adoption of 'other method' under Rule 10AB is not sufficient for valid transfer pricing adjustment: ITAT...
I-T-Re-assessment not tenable where based on incomplete assessment of submitted documents & where no evidence is submitted to prove inadequate cr...
TP - Deduction is available for reversal of provision of doubtful debts which was created and offered to tax during earlier assessment years: ITA...
DTAA - Health & Education Cess cannot be levied on tax determined under DTAA, as tax rate under DTAA is fixed & cannot be further increased by Ce...
 
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