Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
The High Court upheld the assessee's aggregated benchmarking of multiple international transactions under TNMM, accepting the DRP's finding that the transactions were commercially interlinked and should be tested together. Those factual findings were not disturbed by the Tribunal. The Court also applied its earlier ruling in Cummins India Ltd., which recognises that once TNMM is accepted as the most appropriate method, one element cannot be isolated and benchmarked separately if that would distort arm's length determination. As the matter was covered by binding precedent and supported by concurrent findings, no substantial question of law arose and the Revenue's appeal was dismissed.
The High Court upheld the assessee's aggregated benchmarking of multiple international transactions under TNMM, accepting the DRP's finding that the transactions were commercially interlinked and should be tested together. Those factual findings were not disturbed by the Tribunal. The Court also applied its earlier ruling in Cummins India Ltd., which recognises that once TNMM is accepted as the most appropriate method, one element cannot be isolated and benchmarked separately if that would distort arm's length determination. As the matter was covered by binding precedent and supported by concurrent findings, no substantial question of law arose and the Revenue's appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4813 
Join Channel 
