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ITAT Kolkata held that foreign Associated Enterprises are least complex entities and accordingly can be treated as tested parties for comparability analysis of international transaction.
Stay updated on the latest GST portal changes! Learn about disclosures for E-commerce supplies and GSTR-1 amendments effective from January 2024.
ITAT Visakhapatnam has held that if working capital adjustment on ALP has been already factored in pricing/ profitability vis-à-vis that of its comparables, then, no separate upward adjustment on outstanding receivables is required.
ITAT Mumbai held that business restructuring entered into by an enterprise with its associated enterprise for eliminating duplicate corporate procedures falls within the ambit of “international transaction” as defined in section 92B of the Income Tax Act.
ITAT Delhi held that as non-renewal doesn’t amount to termination, accordingly, receipt of compensation on account of non-renewal of contract cannot be taxed under section 28(ii)(e) of the Income Tax Act.
