Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
Customs-controlled container movement now extends to DP World facilities, subject to segregation, inspections, reconciliation, and EXIM cargo priority...
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.
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.
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