Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
High-sea merchant trading conducted through back-to-back USD sales, supported by letters of credit, may justify selecting the foreign associated enterprise as the tested party under the Resale Price Method where the Indian entity bears no significant inventory, collection, market or foreign-exchange risk and has minimal working-capital needs. The associated enterprise's trading margins with unrelated parties can serve as comparable uncontrolled transactions. Steel manufacturers are not functionally comparable to pure merchant traders because their functions, assets and risks materially differ. Currency conversion does not materially affect the analysis where both purchase and sale transactions are denominated in USD.
High-sea merchant trading conducted through back-to-back USD sales, supported by letters of credit, may justify selecting the foreign associated enterprise as the tested party under the Resale Price Method where the Indian entity bears no significant inventory, collection, market or foreign-exchange risk and has minimal working-capital needs. The associated enterprise's trading margins with unrelated parties can serve as comparable uncontrolled transactions. Steel manufacturers are not functionally comparable to pure merchant traders because their functions, assets and risks materially differ. Currency conversion does not materially affect the analysis where both purchase and sale transactions are denominated in USD.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
