Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Authentication of paper assessment orders upheld, while qualifying repairs, consumables and vendor advance write-offs remain deductible business claim...
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The ITAT dismissed challenges to any question of law regarding disallowance of royalty paid by the assessee to its AE, holding that the TPO's role is confined to determining arm's-length price and not to interrogate commercial efficacy; factual findings that manufacturers were subcontractors and no royalty was paid abroad remain uncontroverted. Transfer-pricing adjustments to AMP expenses (both substantive and protective) are deleted, the Tribunal's application of both the intensity approach and the BLT being held not in accordance with law. The assessee's method of valuing opening and closing stock at cost or net realisable value is upheld. The claim for a lower rate of DDT is rejected and decided against the assessee.
The ITAT dismissed challenges to any question of law regarding disallowance of royalty paid by the assessee to its AE, holding that the TPO's role is confined to determining arm's-length price and not to interrogate commercial efficacy; factual findings that manufacturers were subcontractors and no royalty was paid abroad remain uncontroverted. Transfer-pricing adjustments to AMP expenses (both substantive and protective) are deleted, the Tribunal's application of both the intensity approach and the BLT being held not in accordance with law. The assessee's method of valuing opening and closing stock at cost or net realisable value is upheld. The claim for a lower rate of DDT is rejected and decided against the assessee.
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