Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
Cross-examination rights and corroborated evidence limit customs penalties for misdeclaration in genuine import transactions involving documented clea...
Tariff classification of vehicle gear components follows the specific gearing entry, displacing motor-vehicle parts classification and related liabili...
Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
The ITAT directed the AO/TPO to delete the addition for corporate guarantee commission assessed at 0.5% and sustained the assessee's appeal. The Tribunal rejected the protective adjustment of 0.5% as a risk-mitigation factor, holding that the assessee's advance to its associated enterprise (AE) carrying interest at 1.9%-matching the bank's rate-was consistent with arm's-length principles. The ITAT found the AO/TPO's determination of ALP flawed for failing to apply any prescribed method under s.92C and for not undertaking a benchmarking exercise or valuing the specific services received from the AE; consequently the impugned transfer pricing adjustments were set aside and the appeal allowed.
The ITAT directed the AO/TPO to delete the addition for corporate guarantee commission assessed at 0.5% and sustained the assessee's appeal. The Tribunal rejected the protective adjustment of 0.5% as a risk-mitigation factor, holding that the assessee's advance to its associated enterprise (AE) carrying interest at 1.9%-matching the bank's rate-was consistent with arm's-length principles. The ITAT found the AO/TPO's determination of ALP flawed for failing to apply any prescribed method under s.92C and for not undertaking a benchmarking exercise or valuing the specific services received from the AE; consequently the impugned transfer pricing adjustments were set aside and the appeal allowed.
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