Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
Customs-controlled container movement now extends to DP World facilities, subject to segregation, inspections, reconciliation, and EXIM cargo priority...
ITAT addressed transfer pricing adjustment regarding business support services between associated enterprises. TPO rejected assessee's TNMM method and entity-level benchmarking, favoring CUP method. Tribunal found insufficient evidence demonstrating actual service receipt, noting mere documentation (master agreement, work statements, invoices, emails) inadequate to establish genuine service provision. Tribunal determined services appeared to be shareholder cost allocations rather than distinct business services. Due to inadequate documentation distinguishing between cost allocation and actual services rendered, matter remanded to TPO for de-novo adjudication. Issue restored for fresh determination under transfer pricing provisions without prejudice from prior findings. Appeal allowed for statistical purposes.
ITAT addressed transfer pricing adjustment regarding business support services between associated enterprises. TPO rejected assessee's TNMM method and entity-level benchmarking, favoring CUP method. Tribunal found insufficient evidence demonstrating actual service receipt, noting mere documentation (master agreement, work statements, invoices, emails) inadequate to establish genuine service provision. Tribunal determined services appeared to be shareholder cost allocations rather than distinct business services. Due to inadequate documentation distinguishing between cost allocation and actual services rendered, matter remanded to TPO for de-novo adjudication. Issue restored for fresh determination under transfer pricing provisions without prejudice from prior findings. Appeal allowed for statistical purposes.
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