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    TNMM upheld for arm's length pricing; CUP-based transfer pricing adjustment deleted on identical facts.
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A Reach Stacker used exclusively for container handling within a...

Special vehicles confined to enclosed premises fall outside motor vehicle regulation where they are not adapted for road use.

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Customs July 31, 2026 Case Laws SC
A Reach Stacker used exclusively for container handling within a restricted Inland Container Depot is described as falling outside the Motor Vehicles Act, 1988 definition of a motor vehicle because it is a special vehicle adapted only for enclosed premises. The text distinguishes road rollers, which are built for road use, and applies the test of whether a vehicle is adapted for use on roads. Restricted depot roads were not a public place because the public had no right of access. The Reach Stacker's specialised design, excess weight, dismantled transportation, lack of ordinary road-safety features and confined utility supported the exclusion. Non-registration alone was not determinative, but followed from its non-motor-vehicle status.

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Acts Income Tax