Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Customs valuation and classification require comparable evidence and assessment of imported goods in their actual condition, invalidating related pena...
The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) adjustments for both US and non-US transactions. The Tax Authorities computed TP adjustment on the total cost base, including domestic operations, despite resolution of US-related adjustments through Mutual Agreement Procedure. The question was whether domestic operations fall u/s Indian TP provisions. ITAT held that TP should be determined for international transactions u/s Chapter X of Income Tax Act, and domestic TP adjustments must comply with law. The matter was remanded to Assessing Officer/TPO for reassessment of domestic TP adjustments to ensure compliance with law. The appeal was allowed for statistical purposes.
The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) adjustments for both US and non-US transactions. The Tax Authorities computed TP adjustment on the total cost base, including domestic operations, despite resolution of US-related adjustments through Mutual Agreement Procedure. The question was whether domestic operations fall u/s Indian TP provisions. ITAT held that TP should be determined for international transactions u/s Chapter X of Income Tax Act, and domestic TP adjustments must comply with law. The matter was remanded to Assessing Officer/TPO for reassessment of domestic TP adjustments to ensure compliance with law. The appeal was allowed for statistical purposes.
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