Non-participating bidders cannot disturb concluded liquidation sales on speculative prejudice, while costs for such challenges must remain proportiona...
Section 115BBE classification requires a valid deeming-provision basis before special taxation, while the enhanced rate's temporal application remains...
Selection of the most appropriate method for product replacement services supplied at nil sale price depends on the taxpayer's functional profile. Where the taxpayer acts only as a service provider and custodian of imported spares, without setting resale prices, selecting customers, or bearing attendant risks, TNMM applies rather than RPM for arm's-length price recomputation. Comparable selection for benchmarking those services is governed by settled transfer-pricing principles and does not raise a substantial question of law. The erstwhile five per cent tolerance range must be considered when recomputing the arm's-length price in accordance with applicable judicial principles.
Selection of the most appropriate method for product replacement services supplied at nil sale price depends on the taxpayer's functional profile. Where the taxpayer acts only as a service provider and custodian of imported spares, without setting resale prices, selecting customers, or bearing attendant risks, TNMM applies rather than RPM for arm's-length price recomputation. Comparable selection for benchmarking those services is governed by settled transfer-pricing principles and does not raise a substantial question of law. The erstwhile five per cent tolerance range must be considered when recomputing the arm's-length price in accordance with applicable judicial principles.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
