Loading...

⚠ ✕
❮ Top
☎ Help
☰
GST ▸
Central GST ▸
Integrated GST + ▸
UTGST / SGST ▸
GST Case Laws + ▸
Income Tax ▸
Income Tax ▸
Allied (Direct Tax) ▸
Income Tax Case Laws ▸
DTAA ▸
International Taxation ▸
Customs ▸
Customs Act / Rules ▸
Notifications / Forms ▸
Circulars / Tariff ▸
Case Laws / Manual ▸
FTP/SEZ ▸
Foreign Trade ▸
Notifications / Circulars / Appendix / Forms ▸
Special Economic Zone (SEZ) ▸
Corp. Law ▸
Company Laws ▸
Standards / Trusts ▸
Partnership / LLP / Societies ▸
Case Laws ▸
FEMA ▸
FEMA / FCRA ▸
Notifications / Circulars ▸
Manual / FAQ ▸
FEMA Case Laws ▸
SEBI / IBC ▸
SEBI ▸
SEBI Case Laws ▸
IBC ▸
IBC - Case Laws ▸
PMLA ▸
Benami Property ▸
Black Money ▸
Money Laundering ▸
Vivad ▸
Direct Tax ▸
Indirect Taxes ▸
Indian Laws ▸
Indian Laws ▸
Bharatiya Nyaya 2023 ▸
Finance Acts & Bills / Amendment Acts ▸
Case Laws ▸
Labour Laws ▸
Labour Code ▸
Old / Others ▸
Central Excise ▸
Central Excise - Cases ▸
Wealth Tax ▸
Service Tax ▸
Service Tax Cases ▸
CST / DVAT ▸
CST / VAT / Sales Tax ▸
×

By creating an account you can:

Logo TaxTMI
Keyword Search :
AI Tools : New
Ask tax questions in natural language. Powered by AI trained on the TaxTMI legal database. Use AI Tools ➞
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
    6. Text Search
  6. The system will try to fetch results that contains ALL your words.
  7. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
    8. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Filters / Advanced Search ❯
TEXT

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws---- ❯
  • ---- All Laws----
  • Income Tax
  • Direct Taxes
  • Benami Property
  • Central GST Laws
  • SGST - State GST Laws
  • Customs
  • FTP - Foreign Trade Policy
  • SEZ - Special Economic Zone
  • FEMA - Foreign Exchange Management
  • Companies Law
  • SEBI - Securities & Exchange Board of India
  • IBC - Insolvency and Bankruptcy
  • Law of Competition
  • PMLA - Money-Laundering
  • Indian Laws
  • Bill / Finance Bills
  • Wealth Tax
  • Service Tax
  • Central Excise
  • VAT / Sales Tax
Month:
---- All Months ---- ❯
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ---- ❯
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
☰   Show Results ❯
    October 21, 2026   Notifications SEZ
    Domestic Tariff Area returns now permit SEZ Units to resell unaltered goods and repair returned duty-paid goods.
    October 21, 2026   Circulars DGFT
    Tariff rate quota authorisations govern preferential imports of specified New Zealand goods through export certification and electronic customs debiti...
    October 21, 2026   Circulars Customs
    Storage of delayed imported goods requires timely importer notices and records, without altering clearance or disposal procedures.
    October 21, 2026   Circulars Customs
    Electronic Continuity Bond Registration replaces manual container permissions, with quarterly reporting and re-export monitoring for duty-free contain...
    October 21, 2026   Circulars Customs
    Risk-Based Vessel Boarding Enables Electronic Entry Clearance with Heightened Master and Shipping Agent Compliance Duties.
    October 21, 2026   Circulars Customs
    Electronic cargo examination scheduling requires ICEGATE-based booking, automated allocation, audit trails, and reasoned supervisory control over sche...
    October 21, 2026   Circulars Customs
    Custodian and cargo service provider renewal restricts liquid-cargo handling at designated berths, subject to compliance and continuing concession.
    October 21, 2026   Case Laws GST
    Provisional attachment cannot freeze a payment aggregator's escrow funds without tangible material linking it to GST liability.
    October 21, 2026   Case Laws GST
    Assessment jurisdiction transfers require proven searched-group nexus; isolated transactions alone cannot justify inter-State coordinated investigatio...
    October 21, 2026   Case Laws GST
    Service of GST seizure orders is established by signed physical delivery, defeating a non-service challenge to seizure proceedings.
    October 21, 2026   Case Laws GST
    Input tax credit survives supplier deregistration when bona fide purchase evidence is unrebutted and recipient collusion remains unproven.
    October 21, 2026   Case Laws GST
    E-way bill obligations cover internal stock transfers, but penalties fail where bona fide error negates tax-evasion intent.
    October 21, 2026   Case Laws GST
    Specific tariff classification places Ghamella/Tasla under taxable goods provisions rather than the agricultural hand-tool exemption.
    October 21, 2026   Case Laws GST
    Proof of actual diversion is required before GST penalty can override a valid invoice and e-way bill.
    October 21, 2026   Case Laws GST
    Compensation Cess ITC refunds require meeting the inverted-duty statutory test; eligible credit alone does not create cash-refund entitlement.
    October 21, 2026   Case Laws Customs
    Customs sampling powers over imported food coexist with food-safety controls, while testing disputes belong in statutory adjudication.
    October 21, 2026   Case Laws GST
    Delayed transport documents failed to validate intercepted goods, sustaining transit-state penalties where the claimed interstate destination remained...
    October 21, 2026   Case Laws GST
    Inverted tax refunds require independent statutory entitlement; eligible Compensation Cess credit alone does not justify cash refunds for domestic sup...
    October 21, 2026   Case Laws GST
    Compensation Cess refund for domestic supplies requires statutory refund eligibility; credit availment alone does not create entitlement.
    October 21, 2026   Case Laws GST
    E-way bill expiry triggers GST civil penalty without proof of tax-evasion intent where vehicle breakdown lacks credible evidence.
❮
❯
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Open Link
Highlights
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries
October 21, 2026   Notifications SEZ
Domestic Tariff Area returns now permit SEZ Units to resell unaltered goods and repair returned duty-paid goods.
October 21, 2026   Circulars DGFT
Tariff rate quota authorisations govern preferential imports of specified New Zealand goods through export certification and electronic customs debiting.
October 21, 2026   Circulars Customs
Storage of delayed imported goods requires timely importer notices and records, without altering clearance or disposal procedures.
October 21, 2026   Circulars Customs
Electronic Continuity Bond Registration replaces manual container permissions, with quarterly reporting and re-export monitoring for duty-free container imports.
October 21, 2026   Circulars Customs
Risk-Based Vessel Boarding Enables Electronic Entry Clearance with Heightened Master and Shipping Agent Compliance Duties.
October 21, 2026   Circulars Customs
Electronic cargo examination scheduling requires ICEGATE-based booking, automated allocation, audit trails, and reasoned supervisory control over schedule changes.
October 21, 2026   Circulars Customs
Custodian and cargo service provider renewal restricts liquid-cargo handling at designated berths, subject to compliance and continuing concession.
October 21, 2026   Case Laws GST
Provisional attachment cannot freeze a payment aggregator's escrow funds without tangible material linking it to GST liability.
October 21, 2026   Case Laws GST
Assessment jurisdiction transfers require proven searched-group nexus; isolated transactions alone cannot justify inter-State coordinated investigation.
October 21, 2026   Case Laws GST
Service of GST seizure orders is established by signed physical delivery, defeating a non-service challenge to seizure proceedings.
October 21, 2026   Case Laws GST
Input tax credit survives supplier deregistration when bona fide purchase evidence is unrebutted and recipient collusion remains unproven.
October 21, 2026   Case Laws GST
E-way bill obligations cover internal stock transfers, but penalties fail where bona fide error negates tax-evasion intent.
October 21, 2026   Case Laws GST
Specific tariff classification places Ghamella/Tasla under taxable goods provisions rather than the agricultural hand-tool exemption.
October 21, 2026   Case Laws GST
Proof of actual diversion is required before GST penalty can override a valid invoice and e-way bill.
October 21, 2026   Case Laws GST
Compensation Cess ITC refunds require meeting the inverted-duty statutory test; eligible credit alone does not create cash-refund entitlement.
October 21, 2026   Case Laws Customs
Customs sampling powers over imported food coexist with food-safety controls, while testing disputes belong in statutory adjudication.
October 21, 2026   Case Laws GST
Delayed transport documents failed to validate intercepted goods, sustaining transit-state penalties where the claimed interstate destination remained unproved.
October 21, 2026   Case Laws GST
Inverted tax refunds require independent statutory entitlement; eligible Compensation Cess credit alone does not justify cash refunds for domestic supplies.
October 21, 2026   Case Laws GST
Compensation Cess refund for domestic supplies requires statutory refund eligibility; credit availment alone does not create entitlement.
October 21, 2026   Case Laws GST
E-way bill expiry triggers GST civil penalty without proof of tax-evasion intent where vehicle breakdown lacks credible evidence.

Highlights

Back

All Highlights

Showing Results for :
Reset Filters
No Records Found

Highlights

Home › Highlights › Income Tax › 2024 › July, 2024 › This
Back

All Highlights

Income Tax

Transfer Pricing Adjustment - TPO's reliance on loan data from...

Transfer Pricing Adjustment Overturned Due to Bahrain's Unique Conditions; Withholding Tax on Certifications Justified.

Contents
Summary
Note

Note

-

Bookmark

Print

Print

Print Options

Income Tax July 16, 2024 Case Laws AT
Transfer Pricing Adjustment - TPO's reliance on loan data from the US and Europe for benchmarking is inappropriate given Bahrain's distinct economic environment and sovereign risks. The Prime Lending Rate of Bahrain's Central Bank already incorporates regional factors and risks. Adding spreads for country and forex risks constitutes duplicative adjustments. CUP method necessitates adjustments only if materially impacting price. Assessee's consistent application of interest calculation method underscores reliability. CIT(A)'s order upholding fair benchmarking and appropriate risk adjustments is upheld, dismissing TPO's adjustment. Non-deduction of withholding tax u/s 195 - Product Certification Expenses paid to non-residents do not constitute Fees for Technical Services u/s 9(1)(vii). Services involve evaluating technical quality and issuing certificates, not imparting technical knowledge. Payments to entities in USA, UK, Korea, and China are not taxable in India due to no PE.
View Source View

Topics

Acts Income Tax
Next ➔