Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Internal CUP was treated as the most appropriate method for determining the arm's length price of project-office transactions under a turnkey power-project contract. Where the Indian project office bore the contract's risks and rewards, all revenue was attributed to India, and the unrelated customer regarded the head office and project office as one entity, the contract with that customer satisfied the comparability requirements for an internal CUP. CUP was preferred over TNMM as a more direct and suitable method, while the proposed TNMM comparables were rejected. The transfer-pricing adjustment was consequently not sustained, and the appeals were dismissed for lack of a substantial question of law.
Internal CUP was treated as the most appropriate method for determining the arm's length price of project-office transactions under a turnkey power-project contract. Where the Indian project office bore the contract's risks and rewards, all revenue was attributed to India, and the unrelated customer regarded the head office and project office as one entity, the contract with that customer satisfied the comparability requirements for an internal CUP. CUP was preferred over TNMM as a more direct and suitable method, while the proposed TNMM comparables were rejected. The transfer-pricing adjustment was consequently not sustained, and the appeals were dismissed for lack of a substantial question of law.
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