Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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...
Consequential transfer pricing orders were held time-barred because the limitation period depended on the nature of the earlier appellate directions. Where the prior Tribunal order sent the issues on advances to associated enterprises and interest on outstanding receivables back for verification, hearing, and application of directions, the matter was treated as a fresh assessment on remand under section 153(3), with the second proviso to section 153(5) leading to the same result. Where the arm's length commission on corporate guarantees had already been conclusively fixed at 0.5% and only implementation remained, section 153(5) applied. In both situations, the consequential orders passed on 06.12.2024 were beyond time and were set aside.
Consequential transfer pricing orders were held time-barred because the limitation period depended on the nature of the earlier appellate directions. Where the prior Tribunal order sent the issues on advances to associated enterprises and interest on outstanding receivables back for verification, hearing, and application of directions, the matter was treated as a fresh assessment on remand under section 153(3), with the second proviso to section 153(5) leading to the same result. Where the arm's length commission on corporate guarantees had already been conclusively fixed at 0.5% and only implementation remained, section 153(5) applied. In both situations, the consequential orders passed on 06.12.2024 were beyond time and were set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
