Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
ODR arbitration participation remains mandatory after failed conciliation, while jurisdictional and maintainability objections stay available before t...
Transparency in technical bid evaluation requires disclosed standards and recorded reasons; opaque scoring invalidated tender awards and required fres...
Automated export obligation extensions remove separate regional applications after committee approval for Advance Authorisation and EPCG authorisation...
International cargo transhipment through Indian ports continues with Customs-controlled storage, re-export safeguards, and coordinated multi-station m...
Transfer pricing comparables must rest on reliable, internally consistent financial data: MSL Driveline was excluded because its annual report and financial statements conflicted on related party transactions, and the threshold was treated as crossed. Under TNMM, the persistent loss filter turns on operating profit, not profit before tax, and a company with profit in one relevant year is not a persistent loss-maker; Bharat Gears Ltd. and JMT Auto Ltd. were therefore to be included. In a capital-intensive manufacturing business, depreciation differences may warrant adjustment if they materially affect margins. Transfer pricing adjustment is confined to AE transactions, not entity-level non-AE dealings. An intimation under section 143(1) issued after notice under section 143(2) lacked jurisdiction, so the adjustments were deleted.
Transfer pricing comparables must rest on reliable, internally consistent financial data: MSL Driveline was excluded because its annual report and financial statements conflicted on related party transactions, and the threshold was treated as crossed. Under TNMM, the persistent loss filter turns on operating profit, not profit before tax, and a company with profit in one relevant year is not a persistent loss-maker; Bharat Gears Ltd. and JMT Auto Ltd. were therefore to be included. In a capital-intensive manufacturing business, depreciation differences may warrant adjustment if they materially affect margins. Transfer pricing adjustment is confined to AE transactions, not entity-level non-AE dealings. An intimation under section 143(1) issued after notice under section 143(2) lacked jurisdiction, so the adjustments were deleted.
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