Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Social Welfare Surcharge on imports under MEIS/SEIS duty-credit scrips depends on customs duties levied and collected, rather than notional duty quantified or debited under an exemption mechanism. Where notifications exempt goods from basic customs duty and the equivalent amount is debited in scrips, the debit does not constitute actual duty realisation. The surcharge base is therefore nil, making a separate surcharge exemption unnecessary. The Board circular is characterised as clarificatory and applicable to pending earlier-period disputes, while warehousing and education-cess rulings are distinguishable.
Social Welfare Surcharge on imports under MEIS/SEIS duty-credit scrips depends on customs duties levied and collected, rather than notional duty quantified or debited under an exemption mechanism. Where notifications exempt goods from basic customs duty and the equivalent amount is debited in scrips, the debit does not constitute actual duty realisation. The surcharge base is therefore nil, making a separate surcharge exemption unnecessary. The Board circular is characterised as clarificatory and applicable to pending earlier-period disputes, while warehousing and education-cess rulings are distinguishable.
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