Transaction value rejection requires reliable corroboration; refundable VAT is excluded and temporary registration does not defeat new-vehicle exempti...
Appellate jurisdiction remains available where a wrist-worn gold ornament cannot conclusively be characterised as imported baggage at the preliminary ...
Written complaint requirement bars cognizance on police reports for securities offences, while unsupported breach of trust and cheating allegations fa...
Risk-based postal import clearance standardises electronic assessment, document requests, duty realisation and delivery controls at Foreign Post Offic...
Customs Cargo Service Provider appointment extends custodianship to additional terminal land, subject to cargo-control, security and licence condition...
The ITAT set aside the impugned transfer-pricing adjustments and remitted issues to the AO/TPO for fresh determination. With respect to the ITES segment, the Tribunal directed a detailed FAR analysis of transactions with non-UK AEs to assess comparability with UK transactions resolved under the MAP; if comparable, the 18% operating-cost margin agreed by the Competent Authorities shall be applied. The manufacturing-segment comparables were also remitted for a fresh FAR and comparability analysis, with specific instruction to apply related-party, import/export and turnover filters under Rules 10B(2)-10B(3). The addition relating to management charges was dismissed as withdrawn. The assessee to be afforded opportunity of hearing and to furnish documentation.
The ITAT set aside the impugned transfer-pricing adjustments and remitted issues to the AO/TPO for fresh determination. With respect to the ITES segment, the Tribunal directed a detailed FAR analysis of transactions with non-UK AEs to assess comparability with UK transactions resolved under the MAP; if comparable, the 18% operating-cost margin agreed by the Competent Authorities shall be applied. The manufacturing-segment comparables were also remitted for a fresh FAR and comparability analysis, with specific instruction to apply related-party, import/export and turnover filters under Rules 10B(2)-10B(3). The addition relating to management charges was dismissed as withdrawn. The assessee to be afforded opportunity of hearing and to furnish documentation.
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