Coercive recovery during GST searches is restrained pending scrutiny, preserving normal business operations and requiring adherence to investigation g...
COVID-19 limitation exclusion and destination-specific e-way bills govern revisional timelines and penalties for undocumented third-party plywood deli...
Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengea...
Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
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Prescribed transfer-pricing methods must govern arm's length price determination; an ad hoc allocation of consideration between independently negotiated business-transfer and intellectual-property agreements cannot be sustained without comparable analysis, valuation, benchmarking or another recognised methodology. Advertisement, marketing and promotion expenditure alone does not establish economic ownership of marketing intangibles or permit rewriting arm's length agreements absent sham or collusion. The transfer-pricing adjustment was deleted without remand. The dividend distribution tax treaty-rate claim was remitted for action dependent on pending Supreme Court proceedings. Interest for delayed return filing caused by an undisputed e-filing portal glitch was deleted, while the assessment-limitation challenge became infructuous following retrospective amendments.
Prescribed transfer-pricing methods must govern arm's length price determination; an ad hoc allocation of consideration between independently negotiated business-transfer and intellectual-property agreements cannot be sustained without comparable analysis, valuation, benchmarking or another recognised methodology. Advertisement, marketing and promotion expenditure alone does not establish economic ownership of marketing intangibles or permit rewriting arm's length agreements absent sham or collusion. The transfer-pricing adjustment was deleted without remand. The dividend distribution tax treaty-rate claim was remitted for action dependent on pending Supreme Court proceedings. Interest for delayed return filing caused by an undisputed e-filing portal glitch was deleted, while the assessment-limitation challenge became infructuous following retrospective amendments.
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