Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Alternative statutory remedy under GST bars writ challenge where classification, notice variance, and hearing disputes require factual appellate revie...
Transfer-pricing adjustment on raw-material purchases routed through a pass-through associated enterprise is not warranted where the unrelated foreign supplier directly supplies the goods and credit notes reduce the effective price to that supplier's price. An additional invoiced component used solely for customs-duty valuation does not justify an arm's length price adjustment in those circumstances. Compliance with the direction concerning operating revenue results in no further adjustment. The transfer-pricing adjustment on these purchases was deleted and the appeal allowed.
Transfer-pricing adjustment on raw-material purchases routed through a pass-through associated enterprise is not warranted where the unrelated foreign supplier directly supplies the goods and credit notes reduce the effective price to that supplier's price. An additional invoiced component used solely for customs-duty valuation does not justify an arm's length price adjustment in those circumstances. Compliance with the direction concerning operating revenue results in no further adjustment. The transfer-pricing adjustment on these purchases was deleted and the appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
