Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
Cross-examination rights and corroborated evidence limit customs penalties for misdeclaration in genuine import transactions involving documented clea...
Tariff classification of vehicle gear components follows the specific gearing entry, displacing motor-vehicle parts classification and related liabili...
Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
In transfer pricing for the marketing support services segment, the ITAT excluded EDCIL (India) Ltd. because its revenue arose from dealings with Government entities and it was not a proper uncontrolled comparable; it also excluded Just Dial Ltd. for diversified operations, ownership of intangibles and absence of segmental data. Info Edge (India) Ltd. was rejected for its different service profile, multiple web-based businesses and materially different FAR profile, while India Exposition Mart Ltd. was excluded because its exhibition and conference business had a markedly different business model and employee-cost structure. The Tribunal also found that the inclusion of Cyber Media Research & Services Ltd. required verification of conflicting financial statements and remanded that issue to the TPO for fresh consideration after hearing the assessee.
In transfer pricing for the marketing support services segment, the ITAT excluded EDCIL (India) Ltd. because its revenue arose from dealings with Government entities and it was not a proper uncontrolled comparable; it also excluded Just Dial Ltd. for diversified operations, ownership of intangibles and absence of segmental data. Info Edge (India) Ltd. was rejected for its different service profile, multiple web-based businesses and materially different FAR profile, while India Exposition Mart Ltd. was excluded because its exhibition and conference business had a markedly different business model and employee-cost structure. The Tribunal also found that the inclusion of Cyber Media Research & Services Ltd. required verification of conflicting financial statements and remanded that issue to the TPO for fresh consideration after hearing the assessee.
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