Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate ...
Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
Foreign customs declarations and importer admissions established undervaluation, supporting sequential value redetermination, differential duty, and m...
Customs seizure safeguards prevent detention-based limitation avoidance and invalidate provisional release conditions for imported vehicles under an i...
Page of 4828
Press 'Enter' after typing page number.
361 to 380 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT set aside the transfer pricing addition and related disallowance under s.37, rejecting the Revenue's determination of NIL ALP for intra-group services. The Tribunal overturned the TPO/DRP finding that the Taxpayer failed the need, purpose, rendition and benefit tests, held the Taxpayer's corroborative benchmarking (TNMM with the Indian entity as tested party and operating profit/sales as PLI) to be admissible, and directed the TPO to compute the ALP in accordance with that corroborative benchmarking after verifying the PLI computation. The ITAT declined the Revenue's submission equating the TPO approach to the "Other Method" and dismissed the AO/DRP directions disallowing the payments.
The ITAT set aside the transfer pricing addition and related disallowance under s.37, rejecting the Revenue's determination of NIL ALP for intra-group services. The Tribunal overturned the TPO/DRP finding that the Taxpayer failed the need, purpose, rendition and benefit tests, held the Taxpayer's corroborative benchmarking (TNMM with the Indian entity as tested party and operating profit/sales as PLI) to be admissible, and directed the TPO to compute the ALP in accordance with that corroborative benchmarking after verifying the PLI computation. The ITAT declined the Revenue's submission equating the TPO approach to the "Other Method" and dismissed the AO/DRP directions disallowing the payments.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
