Market value for captive electricity consumption follows industrial consumer tariffs, supporting profit computation for the power generation deduction...
Provisional release of seized imports requires enhanced duty payment, bank guarantee and disclosures while customs adjudication proceeds independently...
Transfer-pricing adjustments on interest-free loans to overseas...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallowed.
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Transfer-pricing adjustments on interest-free loans to overseas associated enterprises were deleted because LIBOR-based benchmarking had been accepted on similar facts; continuing corporate guarantees were treated as international transactions, with commission restricted to 0.35%. Premature settlement of deferred sales-tax liability at net present value produced a capital receipt, not taxable remission, and no book-profit adjustment survived. Business losses on unrecovered premises deposits, capital-loan waiver and overseas subsidiary loans and investments were allowed on the stated facts, while property-advance write-offs were disallowed for lack of business nexus. No further exempt-income disallowance or book-profit addition was warranted. Captive-power pricing could use the electricity-board purchase price as a comparable. Uncross-examined third-party statements could not support cargo-expense disallowance, and ESOP claims could be admitted on appeal subject to verification.
Transfer-pricing adjustments on interest-free loans to overseas associated enterprises were deleted because LIBOR-based benchmarking had been accepted on similar facts; continuing corporate guarantees were treated as international transactions, with commission restricted to 0.35%. Premature settlement of deferred sales-tax liability at net present value produced a capital receipt, not taxable remission, and no book-profit adjustment survived. Business losses on unrecovered premises deposits, capital-loan waiver and overseas subsidiary loans and investments were allowed on the stated facts, while property-advance write-offs were disallowed for lack of business nexus. No further exempt-income disallowance or book-profit addition was warranted. Captive-power pricing could use the electricity-board purchase price as a comparable. Uncross-examined third-party statements could not support cargo-expense disallowance, and ESOP claims could be admitted on appeal subject to verification.
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