Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Revision u/s 263 - Whether Tribunal is right in holding that, CBDT Instruction No.3 dated 20.05.2003 is not binding on the AO and as such the AO himself determining the Transfer Pricing adjustment is justified and hence the order of assessment cannot be said to be erroneous - The impugned order passed by the ITAT is clearly unsustainable - HC
Revision u/s 263 - Whether Tribunal is right in holding that, CBDT Instruction No.3 dated 20.05.2003 is not binding on the AO and as such the AO himself determining the Transfer Pricing adjustment is justified and hence the order of assessment cannot be said to be erroneous - The impugned order passed by the ITAT is clearly unsustainable - HC
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