Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
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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