Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
TP adjustment - We are unable to concur with the aforesaid manner in which the TPO had determined the ALP of the referral services rendered by the AE, viz. CLSA, Hong Kong to the assessee at Rs.nil. - Under no circumstances the TPO can benchmark the transactions at nil or in an ad hoc manner by dispensing with the statutory obligation cast upon him to take recourse to and therein determine the ALP by applying any one of the methods prescribed under Sec. 92C(1) of the Act. - AT
TP adjustment - We are unable to concur with the aforesaid manner in which the TPO had determined the ALP of the referral services rendered by the AE, viz. CLSA, Hong Kong to the assessee at Rs.nil. - Under no circumstances the TPO can benchmark the transactions at nil or in an ad hoc manner by dispensing with the statutory obligation cast upon him to take recourse to and therein determine the ALP by applying any one of the methods prescribed under Sec. 92C(1) of the Act. - AT
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