Condonation of delay permits statutory appeal restoration where inadequate service explanation prevented consideration of reassessment and taxable-inc...
Limitation in customs appeals permits exclusion for bona fide refund proceedings, enabling restoration of Bill of Entry assessment challenges on merit...
Warehousing permission requires deposit at the designated bonded warehouse; unauthorised diversion triggers confiscation, redemption fine and importer...
COVID-19 adjustments in transfer-pricing benchmarking require proof of exceptional pandemic expenditure, its non-operating character, and a materially different impact on comparables; pandemic timing alone is insufficient. TNMM also requires consistent treatment of operating and non-operating items for the tested party and comparables, including foreign-exchange effects from revenue transactions and depreciation on business assets. Internal CUP for software support services requires transaction-level comparability of contractual scope, functions, assets, risks, personnel, volume, duration and market conditions, with reliable adjustments for material differences. Transfer-pricing adjustments were remanded for fresh verification and benchmarking. A final assessment following timely draft assessment and DRP directions remains within the separate DRP-related limitation period.
COVID-19 adjustments in transfer-pricing benchmarking require proof of exceptional pandemic expenditure, its non-operating character, and a materially different impact on comparables; pandemic timing alone is insufficient. TNMM also requires consistent treatment of operating and non-operating items for the tested party and comparables, including foreign-exchange effects from revenue transactions and depreciation on business assets. Internal CUP for software support services requires transaction-level comparability of contractual scope, functions, assets, risks, personnel, volume, duration and market conditions, with reliable adjustments for material differences. Transfer-pricing adjustments were remanded for fresh verification and benchmarking. A final assessment following timely draft assessment and DRP directions remains within the separate DRP-related limitation period.
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