Opportunity to respond to jurisdictional reports is mandatory before customs settlement duty enhancement; connected applications require consistent ad...
Specific customs headings for scaffolding components prevail over general classification, invalidating misclassification proceedings and enabling with...
Liquidator appointment under Section 34 requires consideration of creditor recommendations, valid professional authorisation, and preservation of vali...
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TP Adjustment - Eligible International Transaction - safe harbor rules - The court examined the eligibility of international transactions under Rule 10TC of the Income Tax Rules and concluded that certain transactions, including interest on outstanding receivables, did not fall under the scope of Safe Harbour Rules. Therefore, the court rejected the appellant's argument that the Safe Harbour mark-up of 25% precluded any further ALP adjustment. - Regarding the transfer pricing adjustment for interest on outstanding receivables, the ITAT in line with Tribunal decisions, revised the interest rate calculation from LIBOR + 400 basis points to LIBOR + 200 basis points. This adjustment was deemed equitable and balanced for both parties.
TP Adjustment - Eligible International Transaction - safe harbor rules - The court examined the eligibility of international transactions under Rule 10TC of the Income Tax Rules and concluded that certain transactions, including interest on outstanding receivables, did not fall under the scope of Safe Harbour Rules. Therefore, the court rejected the appellant's argument that the Safe Harbour mark-up of 25% precluded any further ALP adjustment. - Regarding the transfer pricing adjustment for interest on outstanding receivables, the ITAT in line with Tribunal decisions, revised the interest rate calculation from LIBOR + 400 basis points to LIBOR + 200 basis points. This adjustment was deemed equitable and balanced for both parties.
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