Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
Royalty-related transfer pricing adjustment was deleted because audited records showed that research and development costs had already been recovered from associated enterprises with a markup of about 10%, making any further adjustment for an alleged unpaid intangible component unwarranted. The adjustment on management support services was also deleted because the assessee had benchmarked interlinked international transactions on an aggregated TNMM basis, and isolating one service for a different method was impermissible. The services, allocation mechanism, and supporting evidence were substantiated, so ALP at nil could not stand.
Royalty-related transfer pricing adjustment was deleted because audited records showed that research and development costs had already been recovered from associated enterprises with a markup of about 10%, making any further adjustment for an alleged unpaid intangible component unwarranted. The adjustment on management support services was also deleted because the assessee had benchmarked interlinked international transactions on an aggregated TNMM basis, and isolating one service for a different method was impermissible. The services, allocation mechanism, and supporting evidence were substantiated, so ALP at nil could not stand.
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