Electronic certificates of origin enable preferential tariffs under the India-New Zealand FTA when format, verification, and filing requirements are m...
Customs approval for liquid cargo exports extends designated jetty operations while existing boarding station and customs area limits remain unchanged...
Mandatory compliance document verification now conditions out-of-charge clearance for imported cosmetics, drugs, and medical devices through PGA-facil...
Double taxation of turnover requires holistic verification across separately registered units and permits limited rectification of overlapping assessm...
ITAT dismissed the Transfer Pricing Officer's notional interest adjustment, holding that intercompany receipts constituted settlement of intra-group receivables leaving no outstanding claim at year-end, so no notional interest was chargeable. Marketing expenses and non-transactional bank charges were excluded from the assessee's PLI computation; operational bank charges supported by segmental accounts may be included. The assessee's artificial segmentation to minimize PLI was rejected. Five contested comparables are to be included after FAR verification, while several others (identified as functionally dissimilar) are excluded. TPO must revisit benchmarking and compute ALP accordingly. The AO is directed to apply corporate tax under s.115BBA after necessary verification. The appeal is partly allowed.
ITAT dismissed the Transfer Pricing Officer's notional interest adjustment, holding that intercompany receipts constituted settlement of intra-group receivables leaving no outstanding claim at year-end, so no notional interest was chargeable. Marketing expenses and non-transactional bank charges were excluded from the assessee's PLI computation; operational bank charges supported by segmental accounts may be included. The assessee's artificial segmentation to minimize PLI was rejected. Five contested comparables are to be included after FAR verification, while several others (identified as functionally dissimilar) are excluded. TPO must revisit benchmarking and compute ALP accordingly. The AO is directed to apply corporate tax under s.115BBA after necessary verification. The appeal is partly allowed.
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