Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Reassessment against a deceased assessee: procedural defect mandates fresh reassessment; nonresponsive petitioner may be treated as legal representati...
Transfer pricing adjustment on purchases from an associated enterprise was disputed, with the assessee benchmarking specified domestic transactions under the CUP method. Since CUP was accepted as the most appropriate method and the assessee's documentation supported that its pricing was at arm's length, the TPO/AO lacked justification to substitute and adjust ALP. The ±5% tolerance was held to be merely a post-determination variation band, and where the charged price falls within that range, no adjustment arises. Consequently, the impugned ALP adjustment on AE purchases was deleted and the appeal was allowed. - ITAT
Transfer pricing adjustment on purchases from an associated enterprise was disputed, with the assessee benchmarking specified domestic transactions under the CUP method. Since CUP was accepted as the most appropriate method and the assessee's documentation supported that its pricing was at arm's length, the TPO/AO lacked justification to substitute and adjust ALP. The ±5% tolerance was held to be merely a post-determination variation band, and where the charged price falls within that range, no adjustment arises. Consequently, the impugned ALP adjustment on AE purchases was deleted and the appeal was allowed. - ITAT
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