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...
Arm's length price of intra-group managerial, testing, validation and engineering services could not be fixed at nil where the assessee had benchmarked the international transactions on an aggregated TNMM basis, shown margins above comparables, and produced documentation on service receipt, business need and benefit; the Tribunal therefore deleted the transfer pricing adjustments. On outstanding receivables, no separate notional interest adjustment survived once the underlying transactions were benchmarked under TNMM with working capital adjustment, so that addition was also deleted. The claim based on payment-basis deduction for leave encashment and bonus was rejected because the disallowance had arisen only in the intimation and not in the draft or final assessment order under appeal.
Arm's length price of intra-group managerial, testing, validation and engineering services could not be fixed at nil where the assessee had benchmarked the international transactions on an aggregated TNMM basis, shown margins above comparables, and produced documentation on service receipt, business need and benefit; the Tribunal therefore deleted the transfer pricing adjustments. On outstanding receivables, no separate notional interest adjustment survived once the underlying transactions were benchmarked under TNMM with working capital adjustment, so that addition was also deleted. The claim based on payment-basis deduction for leave encashment and bonus was rejected because the disallowance had arisen only in the intimation and not in the draft or final assessment order under appeal.
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