Export obligation removed by notification, customs duty demand invalidated; penalties under s.112 and s.114AA quashed due to inadmissible s.108 statem...
Customs officers must wear and use department-issued body-worn cameras when clearing passenger baggage, with daily secure transfer and 30-day retentio...
Page of 4827
Press 'Enter' after typing page number.
10021 to 10040 of 96536 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
