Electronic evidence and search statements in tax assessments require authenticity review and corroboration, while procedural manuals lack statutory fo...
Tariff rate quota authorisations govern preferential imports of specified New Zealand goods through export certification and electronic customs debiti...
Electronic Continuity Bond Registration replaces manual container permissions, with quarterly reporting and re-export monitoring for duty-free contain...
ITAT adjudicated multiple transfer pricing (TP) issues involving associated enterprises (AEs) transactions. The Tribunal comprehensively deleted TP adjustments related to external commercial borrowing (ECB) interest, royalty payments, and trade receivables/payables. Key holdings include: (1) ECB interest at LIBOR+500 basis is arm's length, (2) royalty payment determination at Nil is arbitrary, and (3) netting off notional interest considering both receivables and payables is appropriate. The Tribunal set aside CPC's mechanical adjustments, directing the Assessing Officer to verify suo-moto disallowances and employee contribution issues in accordance with established legal principles and recent judicial precedents.
ITAT adjudicated multiple transfer pricing (TP) issues involving associated enterprises (AEs) transactions. The Tribunal comprehensively deleted TP adjustments related to external commercial borrowing (ECB) interest, royalty payments, and trade receivables/payables. Key holdings include: (1) ECB interest at LIBOR+500 basis is arm's length, (2) royalty payment determination at Nil is arbitrary, and (3) netting off notional interest considering both receivables and payables is appropriate. The Tribunal set aside CPC's mechanical adjustments, directing the Assessing Officer to verify suo-moto disallowances and employee contribution issues in accordance with established legal principles and recent judicial precedents.
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TaxTMI 
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