Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
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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