Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
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 The addition relating to management charges was dismissed as withdrawn.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 The addition relating to management charges was dismissed as withdrawn.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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