Concessional Basic Customs Duty on Ethernet switches: classification as enterprise switches upheld, challenge dismissed for lack of substantial law qu...
Insolvency petition based on admitted debt and default upheld; challenge for malicious initiation rejected, settlement may proceed under resolution fr...
Quashing of FIR and challenge to ECIR over alleged diversion of funds and preferential ESOP pricing dismissed after prima facie money-laundering findi...
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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