Authentication of paper assessment orders upheld, while qualifying repairs, consumables and vendor advance write-offs remain deductible business claim...
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...
Turnover is a relevant comparability filter in transfer pricing for software development services, and applying a ten-times range on both ends for selecting comparables was upheld. Several entities were excluded as functionally dissimilar because they were software product or diversified companies, or because earlier coordinate bench views supported exclusion and no contrary material was shown. Evoke Technologies Ltd. was retained as a comparable since audited records enabled identification of Indian operating revenue and computation of the profit level indicator after excluding overseas branch revenue. The Tribunal also held that benchmarking does not fail merely because only two comparables remain, and dismissed the Revenue's appeal.
Turnover is a relevant comparability filter in transfer pricing for software development services, and applying a ten-times range on both ends for selecting comparables was upheld. Several entities were excluded as functionally dissimilar because they were software product or diversified companies, or because earlier coordinate bench views supported exclusion and no contrary material was shown. Evoke Technologies Ltd. was retained as a comparable since audited records enabled identification of Indian operating revenue and computation of the profit level indicator after excluding overseas branch revenue. The Tribunal also held that benchmarking does not fail merely because only two comparables remain, and dismissed the Revenue's appeal.
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