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 in part. It held that the assessee's application of TNMM with a median margin (6.32%) and reliance on 13 comparables was not rebutted by the TPO, and that existence of a Master Services Agreement and continuous provision of 24/7 support and onsite services by the AE precluded treating the international transaction as at non-arm's length or at Nil ALP; the TP adjustment by AO/TPO was quashed. ITAT observed that denial of deduction for payments invoiced by the AE cannot be sustained merely for lack of a separate work order. With regard to PF/ESI disallowance, ITAT directed the AO to verify whether the assessee had made a suo motu disallowance and, if double disallowance is found, to delete the addition.
ITAT allowed the appeal in part. It held that the assessee's application of TNMM with a median margin (6.32%) and reliance on 13 comparables was not rebutted by the TPO, and that existence of a Master Services Agreement and continuous provision of 24/7 support and onsite services by the AE precluded treating the international transaction as at non-arm's length or at Nil ALP; the TP adjustment by AO/TPO was quashed. ITAT observed that denial of deduction for payments invoiced by the AE cannot be sustained merely for lack of a separate work order. With regard to PF/ESI disallowance, ITAT directed the AO to verify whether the assessee had made a suo motu disallowance and, if double disallowance is found, to delete the addition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
