Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Transfer Pricing Adjustment - Arm's Length Adjustment to Income from Guarantee Commission - Income from Interest on Loans Advanced to Associated Enterprise - The Tribunal emphasized the need for proper benchmarking in determining the arm's length price for these transactions, directing remands to the Assessing Officer and Commissioner for reevaluation. Overall, the appeals were allowed for statistical purposes, with the Tribunal providing detailed instructions for reassessment based on appropriate benchmarks.
Transfer Pricing Adjustment - Arm's Length Adjustment to Income from Guarantee Commission - Income from Interest on Loans Advanced to Associated Enterprise - The Tribunal emphasized the need for proper benchmarking in determining the arm's length price for these transactions, directing remands to the Assessing Officer and Commissioner for reevaluation. Overall, the appeals were allowed for statistical purposes, with the Tribunal providing detailed instructions for reassessment based on appropriate benchmarks.
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