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...
Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
Rectification of DRP directions that changed AMP benchmarking from the earlier approach to intensity-adjusted TNMM, on the CIT(DR)'s application, was unsustainable; the rectified directions and consequential assessment order were set aside. Original DRP directions requiring deletion of a protective AMP adjustment bound the assessment proceedings, so the protective adjustment based on the Bright Line Test was also set aside. AMP transfer-pricing adjustments derived through both the Bright Line Test and intensity-adjusted TNMM were unsustainable for the relevant year and corresponding subsequent years. The impugned assessment orders were set aside, while academic, consequential and unpressed grounds remained open or were not pressed.
Rectification of DRP directions that changed AMP benchmarking from the earlier approach to intensity-adjusted TNMM, on the CIT(DR)'s application, was unsustainable; the rectified directions and consequential assessment order were set aside. Original DRP directions requiring deletion of a protective AMP adjustment bound the assessment proceedings, so the protective adjustment based on the Bright Line Test was also set aside. AMP transfer-pricing adjustments derived through both the Bright Line Test and intensity-adjusted TNMM were unsustainable for the relevant year and corresponding subsequent years. The impugned assessment orders were set aside, while academic, consequential and unpressed grounds remained open or were not pressed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
