Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Royalty payments under a Licence and Technical Assistance Agreement were not addable to the transaction value of imported goods. The agreement covered transfer of technology, technical know-how, and confidential information for manufacturing products, with royalty payable on net sales value. The royalty was not conditional upon import of raw materials. As per the BREMBO case, royalty not linked to imported goods or a condition of sale is not includible in assessable value. The Tribunal held the royalty payments were not addable to the transaction value of imported goods for the period 2012-13 to 2014-15 u/s 14 of the Customs Act, 1962 read with Rule 10(1)(c) of the Customs Valuation Rules, 2007, rejecting the Revenue's appeal.
Royalty payments under a Licence and Technical Assistance Agreement were not addable to the transaction value of imported goods. The agreement covered transfer of technology, technical know-how, and confidential information for manufacturing products, with royalty payable on net sales value. The royalty was not conditional upon import of raw materials. As per the BREMBO case, royalty not linked to imported goods or a condition of sale is not includible in assessable value. The Tribunal held the royalty payments were not addable to the transaction value of imported goods for the period 2012-13 to 2014-15 u/s 14 of the Customs Act, 1962 read with Rule 10(1)(c) of the Customs Valuation Rules, 2007, rejecting the Revenue's appeal.
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