Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Safe Harbour Rules could not be applied suo motu to rework segmental trading costs where the assessee had not opted for that regime and had furnished segmental accounts with allocation keys; the Assessing Officer/Transfer Pricing Officer was directed to adopt the assessee's allocation after verification. An arm's length price of nil for intra-group services was also rejected because the Other Method requires a comparable uncontrolled transaction, which was not shown, and the services had already been aggregated and benchmarked under TNMM, making a separate adjustment a double count. The same reasoning invalidated the lumpsum licence fee adjustment and separate benchmarking of trademark fee. The penalty challenge was dismissed as premature.
Safe Harbour Rules could not be applied suo motu to rework segmental trading costs where the assessee had not opted for that regime and had furnished segmental accounts with allocation keys; the Assessing Officer/Transfer Pricing Officer was directed to adopt the assessee's allocation after verification. An arm's length price of nil for intra-group services was also rejected because the Other Method requires a comparable uncontrolled transaction, which was not shown, and the services had already been aggregated and benchmarked under TNMM, making a separate adjustment a double count. The same reasoning invalidated the lumpsum licence fee adjustment and separate benchmarking of trademark fee. The penalty challenge was dismissed as premature.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4786
Join Channel
TaxTMI 
