Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
The case involves Transfer Pricing (TP) adjustments and the classification of segments for benchmarking purposes. The Appellate Tribunal held that TP adjustments should be based on transactions with Associated Enterprises (AEs) only. The Tribunal directed the Assessing Officer/TPO to consider only the operating profit/cost of AE segments and to apply the Transactional Net Margin Method (TNMM) for services rendered to AEs. The issue of using Resale Price Method (RPM) for the trading segment was also referred back to verify if value addition was made. The classification of the assessee as a manufacturing segment was questioned, and the Tribunal directed verification based on transaction volumes. The Tribunal agreed with the DRP that TP adjustments should be limited to AE transactions only when TNMM is adopted as the Most Appropriate Method (MAM). The appeal was allowed for statistical purposes.
The case involves Transfer Pricing (TP) adjustments and the classification of segments for benchmarking purposes. The Appellate Tribunal held that TP adjustments should be based on transactions with Associated Enterprises (AEs) only. The Tribunal directed the Assessing Officer/TPO to consider only the operating profit/cost of AE segments and to apply the Transactional Net Margin Method (TNMM) for services rendered to AEs. The issue of using Resale Price Method (RPM) for the trading segment was also referred back to verify if value addition was made. The classification of the assessee as a manufacturing segment was questioned, and the Tribunal directed verification based on transaction volumes. The Tribunal agreed with the DRP that TP adjustments should be limited to AE transactions only when TNMM is adopted as the Most Appropriate Method (MAM). The appeal was allowed for statistical purposes.
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