Confiscation and duty recovery quashed where licensing records show export obligation discharged; customs lacks jurisdiction absent licence annulment ...
FOB is Incoterm reflecting exporter's transaction value; declared shipping bill value not automatically confiscable under s.113(i), s.125, ss.114(i) a...
ITAT upheld the assessee's benchmarking and held the arm's-length outcome for the bareboat charter hire arrangement with the associated enterprise; the Tribunal found no merit in the TPO/AO's transfer-pricing adjustment of INR 10,47,30,105 and directed its deletion, allowing grounds 4-10 of the assessee's appeal. The Tribunal relied on the consistent facts and prior DRP acceptance in earlier year, noting comparability and that even after imputing a 2.5% commission the assessee's remuneration remained within comparable limits. The Tribunal further directed the jurisdictional AO to compute interest under s.234C of the Act in accordance with "returned income."
ITAT upheld the assessee's benchmarking and held the arm's-length outcome for the bareboat charter hire arrangement with the associated enterprise; the Tribunal found no merit in the TPO/AO's transfer-pricing adjustment of INR 10,47,30,105 and directed its deletion, allowing grounds 4-10 of the assessee's appeal. The Tribunal relied on the consistent facts and prior DRP acceptance in earlier year, noting comparability and that even after imputing a 2.5% commission the assessee's remuneration remained within comparable limits. The Tribunal further directed the jurisdictional AO to compute interest under s.234C of the Act in accordance with "returned income."
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