Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Transactions with a wholly owned pass-through foreign LLC, whose profits were already taxed in India, were treated as self-dealing rather than separate AE dealings, so no arm's length adjustment survived and the sale adjustment was deleted. Receivables from that same entity were held intrinsically linked to the underlying sales, so the separate interest adjustment was also deleted. For specified domestic transactions, the altered TNMM filters and reduced comparables were found unjustified; the eligible unit's margin fell within the existing range, so the recomputation of profits and related deduction reduction were deleted. The standalone challenge to initiation of penalty proceedings was dismissed as premature.
Transactions with a wholly owned pass-through foreign LLC, whose profits were already taxed in India, were treated as self-dealing rather than separate AE dealings, so no arm's length adjustment survived and the sale adjustment was deleted. Receivables from that same entity were held intrinsically linked to the underlying sales, so the separate interest adjustment was also deleted. For specified domestic transactions, the altered TNMM filters and reduced comparables were found unjustified; the eligible unit's margin fell within the existing range, so the recomputation of profits and related deduction reduction were deleted. The standalone challenge to initiation of penalty proceedings was dismissed as premature.
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