Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
Revisional jurisdiction over export quota premium deductions requires both error and Revenue prejudice; a permissible assessment view cannot be displa...
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Advertisement, marketing and promotion (AMP) expenditure did not constitute an international transaction for transfer-pricing purposes, consistent with earlier orders concerning the assessee. Because an arm's length price adjustment presupposes an international transaction, no adjustment could be made for that expenditure. The deletion of the AMP adjustment was sustained, the Revenue's appeals were dismissed, and the assessee's cross-objections became infructuous.
Advertisement, marketing and promotion (AMP) expenditure did not constitute an international transaction for transfer-pricing purposes, consistent with earlier orders concerning the assessee. Because an arm's length price adjustment presupposes an international transaction, no adjustment could be made for that expenditure. The deletion of the AMP adjustment was sustained, the Revenue's appeals were dismissed, and the assessee's cross-objections became infructuous.
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