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Assessee couldn’t challenge order of ITAT if it had applied amended provisions of MAT pursuant to directions of HC
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Assessee couldn’t challenge order of ITAT if it had applied amended provisions of MAT pursuant to directions of HC
Posted on
on
November 6, 2014
Tenet Tax Daily November 03 2014
By
tenettax-team
Corporate Tax
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Sec. 92CA only empowers TPO to determine ALP of transaction; he can’t reject payment made to AE
ITAT directs AO to decide whether receipt for customized research/retail management services would royalty or FTS
