Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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