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...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
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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