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 allowed the appeal of the assessee and directed the TPO to revise the benchmarking analysis. The Tribunal held that severance pay constitutes a non-operating, extraordinary item and must be excluded from operating costs when computing the assessee's margins for transfer pricing purposes. The Tribunal further directed exclusion of several identified comparables: Comparable A (functionally dissimilar and exhibiting extraordinary profit), Comparable B (functionally superior with advanced product offerings and extraordinary profits), Comparable C (diversified group activities and extraordinary profit), and Comparable D (product development focus previously rejected by the TPO), concluding none were functionally comparable to the assessee's captive software development services.
ITAT allowed the appeal of the assessee and directed the TPO to revise the benchmarking analysis. The Tribunal held that severance pay constitutes a non-operating, extraordinary item and must be excluded from operating costs when computing the assessee's margins for transfer pricing purposes. The Tribunal further directed exclusion of several identified comparables: Comparable A (functionally dissimilar and exhibiting extraordinary profit), Comparable B (functionally superior with advanced product offerings and extraordinary profits), Comparable C (diversified group activities and extraordinary profit), and Comparable D (product development focus previously rejected by the TPO), concluding none were functionally comparable to the assessee's captive software development services.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
