Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
ODR arbitration participation remains mandatory after failed conciliation, while jurisdictional and maintainability objections stay available before t...
Transparency in technical bid evaluation requires disclosed standards and recorded reasons; opaque scoring invalidated tender awards and required fres...
Automated export obligation extensions remove separate regional applications after committee approval for Advance Authorisation and EPCG authorisation...
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The HC affirmed the ITAT's decision that the APA concluded with the revenue was germane to the assessment year, given no change in functions performed, assets employed or risks assumed between the years covered by the APA and the year under scrutiny. The HC held that the TPO/CIT(A) must give effect to the APA's terms - including the agreed arm's-length margin - and reassess transactions accordingly. The Court rejected Revenue's contention that an APA is confined to the specific years agreed and cannot inform statutory transfer-pricing determination where FARs are unchanged, directing the assessing authorities to apply the APA's consolidated margin (19.26%) and FAR analysis in the assessment.
The HC affirmed the ITAT's decision that the APA concluded with the revenue was germane to the assessment year, given no change in functions performed, assets employed or risks assumed between the years covered by the APA and the year under scrutiny. The HC held that the TPO/CIT(A) must give effect to the APA's terms - including the agreed arm's-length margin - and reassess transactions accordingly. The Court rejected Revenue's contention that an APA is confined to the specific years agreed and cannot inform statutory transfer-pricing determination where FARs are unchanged, directing the assessing authorities to apply the APA's consolidated margin (19.26%) and FAR analysis in the assessment.
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