Courier transshipment of imported goods via named carrier to air cargo stations renewed until 30.01.2026; exemption conditional, strict controls apply...
Insurer's investment gains and investment write-downs face Section 263 revision; enquiry upheld, Rule 5(b)(ii) lapse sustained, late corrigendum quash...
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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