Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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The Income Tax Appellate Tribunal (ITAT) held that the assessee's transactions involving purchases and sales on a High Seas Sales (HSS) basis did not constitute speculative transactions. The ITAT observed that under the Act, the term "speculation" focuses on whether the transactions involve actual delivery, transfer, or settlement. In the assessee's case, the entire transaction involved a process where delivery of goods took place, evidenced by documents like the Bill of Lading, which was not disputed by the revenue authorities. The ITAT found that the assessee physically purchased goods from a foreign seller, sold them to an importer while on high seas, and the ultimate buyer took delivery by filing the bill of entry and complying with customs formalities. Since the factual sequence of events and documentary evidence regarding the ultimate delivery were not disputed, the ITAT concluded that the transactions did not amount to speculation. Consequently, the assessee's appeal was allowed.
The Income Tax Appellate Tribunal (ITAT) held that the assessee's transactions involving purchases and sales on a High Seas Sales (HSS) basis did not constitute speculative transactions. The ITAT observed that under the Act, the term "speculation" focuses on whether the transactions involve actual delivery, transfer, or settlement. In the assessee's case, the entire transaction involved a process where delivery of goods took place, evidenced by documents like the Bill of Lading, which was not disputed by the revenue authorities. The ITAT found that the assessee physically purchased goods from a foreign seller, sold them to an importer while on high seas, and the ultimate buyer took delivery by filing the bill of entry and complying with customs formalities. Since the factual sequence of events and documentary evidence regarding the ultimate delivery were not disputed, the ITAT concluded that the transactions did not amount to speculation. Consequently, the assessee's appeal was allowed.
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