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 - arm's length price of broking commission - selection of most appropriate method - considering brokerage rate of all non-associates for comparability - TPO rejected TNMM, applied CUP method - directed to consider both overseas and domestic clients while applying CUP method. No adjustment of marketing cost while applying CUP method, not granting adjustment of research cost and volume - directed to allow 40% adjustment on marketing and research cost. Computing upward adjustment by considering addition instead of rectified amount - issue restored to AO for giving effect as per TPO's rectification order. Disallowance of net loss incurred on error trading transactions - directed to allow as incidental to assessee's broking business. Disallowance u/s 14A - issue remanded to AO to examine disallowance and assessee to substantiate claim.
Transfer pricing adjustment - arm's length price of broking commission - selection of most appropriate method - considering brokerage rate of all non-associates for comparability - TPO rejected TNMM, applied CUP method - directed to consider both overseas and domestic clients while applying CUP method. No adjustment of marketing cost while applying CUP method, not granting adjustment of research cost and volume - directed to allow 40% adjustment on marketing and research cost. Computing upward adjustment by considering addition instead of rectified amount - issue restored to AO for giving effect as per TPO's rectification order. Disallowance of net loss incurred on error trading transactions - directed to allow as incidental to assessee's broking business. Disallowance u/s 14A - issue remanded to AO to examine disallowance and assessee to substantiate claim.
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