Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
A unilateral advance pricing agreement fixing a consolidated 1.9% of net sales for royalty and fees for technical services was treated as highly persuasive guidance for comparability analysis where the transactions were similar. On that basis, the royalty and technical fee adjustment was found excessive, and the Assessing Officer was directed to cap the rate at 1.9% of net sales in line with the CBDT-accepted APA. The remaining grounds were left open or treated as consequential.
A unilateral advance pricing agreement fixing a consolidated 1.9% of net sales for royalty and fees for technical services was treated as highly persuasive guidance for comparability analysis where the transactions were similar. On that basis, the royalty and technical fee adjustment was found excessive, and the Assessing Officer was directed to cap the rate at 1.9% of net sales in line with the CBDT-accepted APA. The remaining grounds were left open or treated as consequential.
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