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...
For import of finished goods by a routine distributor, RPM was treated as the most appropriate transfer pricing method because the assessee merely resold the imported products without processing, physical alteration, or value addition, and no local intangibles were shown. Advertising, sales and distribution expenditure below the gross profit line did not affect RPM analysis, so rejection of RPM in favour of TNMM was unwarranted. Interest under the relevant provisions was left to follow the assessment outcome, while the challenge to initiation of penalty proceedings was held premature.
For import of finished goods by a routine distributor, RPM was treated as the most appropriate transfer pricing method because the assessee merely resold the imported products without processing, physical alteration, or value addition, and no local intangibles were shown. Advertising, sales and distribution expenditure below the gross profit line did not affect RPM analysis, so rejection of RPM in favour of TNMM was unwarranted. Interest under the relevant provisions was left to follow the assessment outcome, while the challenge to initiation of penalty proceedings was held premature.
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