Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Valuation of imports from related suppliers and the inclusion or exclusion of royalty in the transaction value. The key points are: Rule 10(1)(c) of the Customs Valuation Rules, 2007 allows for the addition of royalty to the transaction value of imported goods. The Supreme Court in CC vs. M/s Ferodo India Pvt Ltd examined the issue and held that technical know-how and royalty payment are includible in the price of imported goods if it is a prerequisite for the supply by the foreign supplier. However, in the present case, the pricing was at arm's length, and the relationship did not influence the price, which was accepted by the department in past transactions between the same parties. The Commissioner (Appeals) rightly held that there was no question of adding royalty to the transaction value. The CESTAT dismissed the Revenue's appeal, considering the Supreme Court's decision in CC vs. M/s Ferodo India Pvt Ltd.
Valuation of imports from related suppliers and the inclusion or exclusion of royalty in the transaction value. The key points are: Rule 10(1)(c) of the Customs Valuation Rules, 2007 allows for the addition of royalty to the transaction value of imported goods. The Supreme Court in CC vs. M/s Ferodo India Pvt Ltd examined the issue and held that technical know-how and royalty payment are includible in the price of imported goods if it is a prerequisite for the supply by the foreign supplier. However, in the present case, the pricing was at arm's length, and the relationship did not influence the price, which was accepted by the department in past transactions between the same parties. The Commissioner (Appeals) rightly held that there was no question of adding royalty to the transaction value. The CESTAT dismissed the Revenue's appeal, considering the Supreme Court's decision in CC vs. M/s Ferodo India Pvt Ltd.
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