Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
Diagnostic microcuvette classification follows sole-use analytical function, placing specialised disposable cuvettes with their analyser rather than g...
The ITAT Hyderabad upheld the Corporate Guarantee Commission at 0.53% for guarantees to foreign AEs, rejecting the AO's 1.8% rate. The tribunal determined the pro rata guarantee at 30.50% of a $10 million loan balance. The CIT(A) classified corporate guarantees as international transactions and set the commission at 0.53%. Interest on trade receivables was benchmarked at 6% SBI rate. The tribunal remanded R&D, Head Office, and Marketing expenses issues back to the AO/TPO for fresh assessment, citing a violation of natural justice. The tribunal directed the assessee to provide segmental accounts for accurate benchmarking. The tribunal excluded certain comparables based on RPT filter agreement.
The ITAT Hyderabad upheld the Corporate Guarantee Commission at 0.53% for guarantees to foreign AEs, rejecting the AO's 1.8% rate. The tribunal determined the pro rata guarantee at 30.50% of a $10 million loan balance. The CIT(A) classified corporate guarantees as international transactions and set the commission at 0.53%. Interest on trade receivables was benchmarked at 6% SBI rate. The tribunal remanded R&D, Head Office, and Marketing expenses issues back to the AO/TPO for fresh assessment, citing a violation of natural justice. The tribunal directed the assessee to provide segmental accounts for accurate benchmarking. The tribunal excluded certain comparables based on RPT filter agreement.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4884 
