Direct Tax

TP – Aggregation of Transactions – Where payment made by assessee to AE towards cost contribution charges was integral part of core business of assessee and, therefore, transaction of cost contribution charges was aggregated with transactions related to business and benchmarked under TNMM, TPO was not justified in applying CUP as most appropriate method for computing ALP of cost contribution charges treating same as separate class of transactions.

Ingersoll Rand Technologies and Services (P.) Ltd v. Assistant Commissioner of Income-tax – [2022] 140 taxmann.com 135 (Bangalore-Trib.).

CBDT mandates e-filing of certain forms, returns or statements.

Notification No. 03/2022, dated 16-07-2022.

Company should be engaged in money lending business is not a criterion to allow claim of bad debts on money advanced.

Pranava Electronics (P.) Ltd. v. DCIT – [2-22] 140 taxmann.com 9 (Bangalore-Trib.).

Sufficiency or inadequacy of reasons to believe cannot be examined while considering validity of search.

PCIT (Investigation) v. Laljibhai Kanjibhai Mandalia – [2022] 140 taxmann.com 282 (SC).

CBDT notifies Form 8A to make application u/s 158AB to defer filing of appeal on identical issues.

Notification No. 83/2022, dated 12-07-2022.

194J – Where dominant purpose of contract is supply of rolling stock and service component is negligible, no TDS is deductible u/s 194J.

Commissioner of Income-tax v. Bangalore Metro Raid Corporation Ltd. – [2022] 140 taxmann.com 229 (Karnataka).