International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
Disallowance of payments for intra-group services to an associated enterprise was examined on whether services were actually rendered and whether they were duplicative, stewardship, incidental, or on-call. Based on the nature and scale of operations, centralized group support, and audited accounts showing no double-claim of expenses, the tribunal held that the services were received and the expenditure was incurred; however, since the TPO had not examined the assessee's ALP under the prescribed approach despite TNMM being adopted, ALP determination was remanded to the TPO and the related grounds were allowed for statistical purposes. The challenge to the DRP/TPO's use of "other method" without comparables was rejected as meritless and dismissed. - ITAT
Disallowance of payments for intra-group services to an associated enterprise was examined on whether services were actually rendered and whether they were duplicative, stewardship, incidental, or on-call. Based on the nature and scale of operations, centralized group support, and audited accounts showing no double-claim of expenses, the tribunal held that the services were received and the expenditure was incurred; however, since the TPO had not examined the assessee's ALP under the prescribed approach despite TNMM being adopted, ALP determination was remanded to the TPO and the related grounds were allowed for statistical purposes. The challenge to the DRP/TPO's use of "other method" without comparables was rejected as meritless and dismissed. - ITAT
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