Transaction value rejection requires reliable corroboration; refundable VAT is excluded and temporary registration does not defeat new-vehicle exempti...
Appellate jurisdiction remains available where a wrist-worn gold ornament cannot conclusively be characterised as imported baggage at the preliminary ...
Written complaint requirement bars cognizance on police reports for securities offences, while unsupported breach of trust and cheating allegations fa...
Risk-based postal import clearance standardises electronic assessment, document requests, duty realisation and delivery controls at Foreign Post Offic...
Customs Cargo Service Provider appointment extends custodianship to additional terminal land, subject to cargo-control, security and licence condition...
In transfer pricing under TNMM, the ITAT treated regular foreign exchange gain as operating income, held that common Delhi and Dehradun expenses had to be allocated on gross profit margins rather than turnover, and applied broad functional comparability to accept the five comparables; it also rejected exclusion of Gontermann Pieper as a persistent loss-maker because it had not suffered losses for three consecutive years. The transfer pricing adjustment was therefore restored to the TPO/AO for recomputation on those terms. On interest deduction, the ITAT applied CIT v. Rajendra Prasad Moody and allowed interest expenditure against interest income, holding that absence of dividend from the subsidiary investment did not justify disallowance. The interest disallowance was deleted.
In transfer pricing under TNMM, the ITAT treated regular foreign exchange gain as operating income, held that common Delhi and Dehradun expenses had to be allocated on gross profit margins rather than turnover, and applied broad functional comparability to accept the five comparables; it also rejected exclusion of Gontermann Pieper as a persistent loss-maker because it had not suffered losses for three consecutive years. The transfer pricing adjustment was therefore restored to the TPO/AO for recomputation on those terms. On interest deduction, the ITAT applied CIT v. Rajendra Prasad Moody and allowed interest expenditure against interest income, holding that absence of dividend from the subsidiary investment did not justify disallowance. The interest disallowance was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
