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 issues: Royalty arrangement including trademark, know-how upheld based on CUP method over TNMM. Advertisement expenses remanded for fresh determination. Reimbursement of third-party advertisement expenses deleted as commercial expediency beyond TPO's jurisdiction. IT cost allocation and consultancy services/HR cost reimbursements deleted following past orders. Comparables for marketing support services: APITCO, HCCA Business Services, Quippo Valuers, TSR Darashaw excluded; ITDC (ARMS segment), Overseas Manpower, ICRA Management Consulting included based on functional comparability and consistency. TPO directed to recompute ALP for marketing support services accordingly.
Transfer pricing issues: Royalty arrangement including trademark, know-how upheld based on CUP method over TNMM. Advertisement expenses remanded for fresh determination. Reimbursement of third-party advertisement expenses deleted as commercial expediency beyond TPO's jurisdiction. IT cost allocation and consultancy services/HR cost reimbursements deleted following past orders. Comparables for marketing support services: APITCO, HCCA Business Services, Quippo Valuers, TSR Darashaw excluded; ITDC (ARMS segment), Overseas Manpower, ICRA Management Consulting included based on functional comparability and consistency. TPO directed to recompute ALP for marketing support services accordingly.
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