The issue concerned an upward transfer pricing adjustment on corporate guarantee fees charged to AEs. The Tribunal upheld the fee at 0.25% as arm’s length, citing prior ITAT precedents. The takeaway: valid comparable data and indemnification protect against such adjustments.
The Tribunal held that revenue-sharing license fees under the 1999 policy are capital expenditure, mandatorily amortizable under section 35ABB, following the Supreme Court verdict.
The Tribunal held that cash deposits arising from recorded pharmacy sales during demonetisation cannot be added under section 68 when turnover is accepted and duly taxed.
Cash deposits during demonetisation were held genuine where supported by EMI recoveries from thousands of borrowers, with no enquiry or evidence to treat them as unexplained.
Tribunal confirmed that transfer of passive infrastructure assets is genuine and qualifies as a gift under section 47(iii), rejecting revenue’s claim of tax avoidance.
Transfer pricing adjustment of ₹21.88 lakh partly reduced to 0.5% corporate guarantee fee. Tribunal confirms international transaction status but applies consistent methodology with prior years.
Section 87A rebate allows resident individuals with income under specified limits to reduce their tax liability to zero, clarifying the “no tax” claim.
Ethical conduct is the core of professional credibility in accountancy, directly influencing career prospects, client trust, and regulatory acceptance worldwide.
Courts have held that failure to serve mandatory pre-adjudication notices violates statutory procedure and invalidates GST proceedings.
The Tribunal examined opening cash balance of ₹6.16 lakh brought forward from prior year. CIT(A) had disallowed it, but AO verification confirmed its genuineness. ITAT set aside the addition under Section 69A and allowed the appeal.
