Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
ITAT set aside the CIT(A) order and restored the case to the file of the AO/TPO for de novo adjudication, holding that neither the assessee's nor the TPO's CUP comparables met Rule 10B(2)/(3) comparability standards; the AO/TPO is directed to reassess ALP after identifying or constructing reliable comparables and making appropriate adjustments (including for convertibility/option value, subordination, security, industry risk and coupon structure). The Tribunal also remitted disputed legal/professional, advertising and commission expenses to the AO for verification and determination as capitalisable WIP or allowable revenue expenditure. The Revenue's appeal is allowed for statistical purposes.
ITAT set aside the CIT(A) order and restored the case to the file of the AO/TPO for de novo adjudication, holding that neither the assessee's nor the TPO's CUP comparables met Rule 10B(2)/(3) comparability standards; the AO/TPO is directed to reassess ALP after identifying or constructing reliable comparables and making appropriate adjustments (including for convertibility/option value, subordination, security, industry risk and coupon structure). The Tribunal also remitted disputed legal/professional, advertising and commission expenses to the AO for verification and determination as capitalisable WIP or allowable revenue expenditure. The Revenue's appeal is allowed for statistical purposes.
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