Transaction value rejection requires reliable corroboration; refundable VAT is excluded and temporary registration does not defeat new-vehicle exempti...
Appellate jurisdiction remains available where a wrist-worn gold ornament cannot conclusively be characterised as imported baggage at the preliminary ...
Written complaint requirement bars cognizance on police reports for securities offences, while unsupported breach of trust and cheating allegations fa...
Risk-based postal import clearance standardises electronic assessment, document requests, duty realisation and delivery controls at Foreign Post Offic...
Customs Cargo Service Provider appointment extends custodianship to additional terminal land, subject to cargo-control, security and licence condition...
The ITAT Mumbai held that the Transfer Pricing Officer (TPO) unjustifiably rejected the benchmarking analysis done by the assessee for determining the Arm's Length Price (ALP) of services. The TPO's adhoc estimation lacked proper basis and reasoning, while the assessee's detailed analysis and need and benefit test were found to be satisfactory. The TPO's rejection of the benchmarking using the associated enterprise as a tested party was deemed incorrect, as the foreign associated enterprise was accepted as a tested party for benchmarking. The TPO's adhoc determination of TP adjustment was rejected, and the MAT credit entitlement issue was directed for further verification. The disallowance under section 14A r.w.r. 8D was deleted as the assessee did not claim dividend income as exempt.
The ITAT Mumbai held that the Transfer Pricing Officer (TPO) unjustifiably rejected the benchmarking analysis done by the assessee for determining the Arm's Length Price (ALP) of services. The TPO's adhoc estimation lacked proper basis and reasoning, while the assessee's detailed analysis and need and benefit test were found to be satisfactory. The TPO's rejection of the benchmarking using the associated enterprise as a tested party was deemed incorrect, as the foreign associated enterprise was accepted as a tested party for benchmarking. The TPO's adhoc determination of TP adjustment was rejected, and the MAT credit entitlement issue was directed for further verification. The disallowance under section 14A r.w.r. 8D was deleted as the assessee did not claim dividend income as exempt.
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