Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
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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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