Authentication of paper assessment orders upheld, while qualifying repairs, consumables and vendor advance write-offs remain deductible business claim...
Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
Cross-examination rights and corroborated evidence limit customs penalties for misdeclaration in genuine import transactions involving documented clea...
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Corporate guarantees to subsidiaries are described as shareholder activities but, following retrospective inclusion within capital financing, remain international transactions requiring arm's length benchmarking; the guarantee commission was restricted to 0.5%. Omission without a saving clause of the specified domestic transaction category for related-party expenditure invalidated the related transfer-pricing reference and adjustment. Common head-office costs may be allocated at cost among eligible and non-eligible units because the head office is a cost centre, not an independent service provider. Interest-free advances to overseas associated enterprises require arm's length interest benchmarking despite own funds or commercial expediency. Recurring advertisement, brand-promotion and market-research expenditure was treated as revenue expenditure, not capital expenditure.
Corporate guarantees to subsidiaries are described as shareholder activities but, following retrospective inclusion within capital financing, remain international transactions requiring arm's length benchmarking; the guarantee commission was restricted to 0.5%. Omission without a saving clause of the specified domestic transaction category for related-party expenditure invalidated the related transfer-pricing reference and adjustment. Common head-office costs may be allocated at cost among eligible and non-eligible units because the head office is a cost centre, not an independent service provider. Interest-free advances to overseas associated enterprises require arm's length interest benchmarking despite own funds or commercial expediency. Recurring advertisement, brand-promotion and market-research expenditure was treated as revenue expenditure, not capital expenditure.
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