Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
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Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
ITAT adjudicated a transfer pricing dispute involving international transactions. The tribunal upheld the TPO's rejection of the assessee's transfer pricing study, determining that the tested party should be indigenous rather than foreign affiliated entities. The ITAT mandated adoption of the Comparable Uncontrolled Price (CUP) method for benchmarking and validated Kotak as a suitable comparable, subject to specific service comparisons. The tribunal critically noted that the TPO should comprehensively examine evidence regarding intra-group services, emphasizing the need for thorough analysis of arm's length pricing mechanisms. The decision underscores the importance of substantive evidence and proper transfer pricing methodology in evaluating cross-border transactions, ultimately remanding the matter for detailed quantitative assessment consistent with income tax regulations.
ITAT adjudicated a transfer pricing dispute involving international transactions. The tribunal upheld the TPO's rejection of the assessee's transfer pricing study, determining that the tested party should be indigenous rather than foreign affiliated entities. The ITAT mandated adoption of the Comparable Uncontrolled Price (CUP) method for benchmarking and validated Kotak as a suitable comparable, subject to specific service comparisons. The tribunal critically noted that the TPO should comprehensively examine evidence regarding intra-group services, emphasizing the need for thorough analysis of arm's length pricing mechanisms. The decision underscores the importance of substantive evidence and proper transfer pricing methodology in evaluating cross-border transactions, ultimately remanding the matter for detailed quantitative assessment consistent with income tax regulations.
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