Handicraft job work receives concessional GST only for registered principals and predominantly handmade goods; commercial resin articles remain taxabl...
Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination b...
Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
ITAT allowed the assessee's appeal on transfer pricing, holding that for the international transaction of import of finished goods from its AE, the assessee functions as a routine distributor with no value addition, assuming limited risks, while the AE is the principal undertaking manufacturing, HQ and marketing functions and major risks. Accordingly, the assessee was rightly treated as the tested party and Resale Price Method (RPM), with PLI of gross profit to sales, was held to be the Most Appropriate Method instead of TNMM. The TP adjustment made by the TPO/AO was thereby held unsustainable.
ITAT allowed the assessee's appeal on transfer pricing, holding that for the international transaction of import of finished goods from its AE, the assessee functions as a routine distributor with no value addition, assuming limited risks, while the AE is the principal undertaking manufacturing, HQ and marketing functions and major risks. Accordingly, the assessee was rightly treated as the tested party and Resale Price Method (RPM), with PLI of gross profit to sales, was held to be the Most Appropriate Method instead of TNMM. The TP adjustment made by the TPO/AO was thereby held unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
