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    Royalty and management support service adjustments fail where costs were recovered and aggregated TNMM benchmarking applied.
    Transfer pricing adjustments remanded for fresh review of intra-group services, sensor assembling method and comparables analysis
    Foreign asset disclosure in a substituted return can defeat penalty for an earlier omission when assessment accepts it.
    Comparability filters in TNMM require upfront R&D screening and broadly similar turnover scales for software services.
    Functional comparability in wholesale auto-component trading excludes retail and after-sales comparables, deleting transfer pricing adjustments
    Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
    Pass-through LLC self-dealing defeats transfer pricing adjustment; linked receivables and profit recomputation were also deleted.
    Transfer pricing comparability: predominantly manufacturing comparables were excluded, and IT support charges were not fixed at nil.
    Substantial compliance in transfer pricing documentation defeats penalty for diamond trade record shortfall where arm's length pricing stood accepted
    Double taxation through rectification was impermissible where income already shown under proper heads was added again to business income.
    Bona fide return error defeats misreporting penalty where no specific statutory clause is identified in assessment.
    Interest computation in return processing restored for fresh factual verification and de novo adjudication.
    Revisional power under section 264 cannot worsen assessee's position; cash deposits explained from past salary savings.
    Fair market value of surrendered tenancy rights can determine cost of acquisition for redeveloped property gains
    Customs valuation enhancement fails when based on a retracted statement and non-comparable contemporaneous import invoices.
    Transportation charges and foreign-branch services were held outside service tax, while disclosed records defeated extended limitation.
    Negative list treatment for food grain transport without consignment notes defeats service tax and extended limitation demand.
    Arbitration clause confined to work-execution disputes; tax reimbursement claim under separate taxes clause was non-arbitrable on referral review.
    Financial intelligence sharing expanded to include the Directorate of Naval Intelligence under the PMLA notification.
    Common adjudicating authority appointed for specified customs show cause notices against an importer
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This document provides guidance on compounding of contraventions...

Guide to Compounding Violations Under FEMA: Eligibility, Application Steps, and Penalty Calculation Explained.

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FEMA October 3, 2024 Circulars
This document provides guidance on compounding of contraventions under the Foreign Exchange Management Act (FEMA), 1999. It outlines the process, eligibility criteria, and computation matrix for determining the compounding amount payable for various types of contraventions. Key points: - Certain contraventions related to foreign investment, external commercial borrowings, overseas investment, and branch/liaison offices can be compounded by RBI's Regional Offices. - Applicants must submit a compounding application along with the prescribed fee of Rs. 10,000 plus GST. - Cases involving serious contraventions like money laundering, terror financing, or affecting national sovereignty are not eligible for compounding. - The compounding amount is calculated based on factors such as the sum involved, duration of contravention, undue gains made, and repetitive nature of the contravention. - A detailed computation matrix with formulas is provided for calculating the compounding amount for different types of contraventions. - The compounding authority will pass an order after giving the applicant an opportunity for a personal hearing. - The compounded amount must be paid within 15 days from the date of the compounding order. - Summary information about compounding orders will be hosted on RBI's website. The document also covers procedural aspects like submission of applications, payment modes, and issuance of compounding orders.

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Acts Income Tax