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...
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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