Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
TP Adjustment - determination of Arm’s Length Price (ALP) - The products are unique and not comparable to others. The terms and conditions and the economic circumstances under which the Assessee sells extruders parts and elements to AE are materially different from the comparable uncontrolled transactions. We are therefore of the view that the question of adopting the profit margins at the entity level based on the submissions made by the Assessee before the CIT(A) cannot be accepted. - AT
TP Adjustment - determination of Arm’s Length Price (ALP) - The products are unique and not comparable to others. The terms and conditions and the economic circumstances under which the Assessee sells extruders parts and elements to AE are materially different from the comparable uncontrolled transactions. We are therefore of the view that the question of adopting the profit margins at the entity level based on the submissions made by the Assessee before the CIT(A) cannot be accepted. - AT
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