Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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