Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through agreement, correspondence, invoices, payments, and improved revenue and profitability. The Dispute Resolution Panel arbitrarily upheld the Transfer Pricing Officer's determination of nil value without examining facts and legal precedents. The Tribunal set aside the adjustment, reinstating the assessee's transfer pricing analysis using the Transactional Net Margin Method. Regarding imputed interest on delayed receivables, the Tribunal followed precedents that working capital adjustment subsumes interest on receivables, eliminating separate benchmarking. As the assessee's profit level indicators after working capital adjustment were better than comparables, imputing notional interest was unwarranted. The interest adjustment was deleted in favor of the assessee.
Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through agreement, correspondence, invoices, payments, and improved revenue and profitability. The Dispute Resolution Panel arbitrarily upheld the Transfer Pricing Officer's determination of nil value without examining facts and legal precedents. The Tribunal set aside the adjustment, reinstating the assessee's transfer pricing analysis using the Transactional Net Margin Method. Regarding imputed interest on delayed receivables, the Tribunal followed precedents that working capital adjustment subsumes interest on receivables, eliminating separate benchmarking. As the assessee's profit level indicators after working capital adjustment were better than comparables, imputing notional interest was unwarranted. The interest adjustment was deleted in favor of the assessee.
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