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...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
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Transfer Pricing Adjustments - The Tribunal reaffirmed the primacy of the TNMM over CUP for benchmarking certain types of transactions, especially when comparable data for CUP is not readily available or applicable. - The ruling emphasized the reduced rate of taxation on interest income from foreign currency loans under specific conditions, thereby clarifying the applicability of section 115A over normal tax rates. - The allowance of deductions under section 44C was confirmed, highlighting the importance of adhering to the statutory limits and maintaining proper documentation to support such claims. - Lastly, the Tribunal's interpretation of the India-Canada DTAA in the context of taxability of interest on income tax refunds signals a broader understanding of DTAAs' provisions, particularly regarding the exemptions available to non-residents.
Transfer Pricing Adjustments - The Tribunal reaffirmed the primacy of the TNMM over CUP for benchmarking certain types of transactions, especially when comparable data for CUP is not readily available or applicable. - The ruling emphasized the reduced rate of taxation on interest income from foreign currency loans under specific conditions, thereby clarifying the applicability of section 115A over normal tax rates. - The allowance of deductions under section 44C was confirmed, highlighting the importance of adhering to the statutory limits and maintaining proper documentation to support such claims. - Lastly, the Tribunal's interpretation of the India-Canada DTAA in the context of taxability of interest on income tax refunds signals a broader understanding of DTAAs' provisions, particularly regarding the exemptions available to non-residents.
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