Appellate jurisdiction over baggage imports is excluded, requiring confiscation challenges involving passenger-carried gold to proceed by statutory re...
Article 227 review permits intervention in arbitration only for manifest, patent inherent jurisdictional defects, not representational authority dispu...
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 4891 
