Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
Customs-controlled container movement now extends to DP World facilities, subject to segregation, inspections, reconciliation, and EXIM cargo priority...
Transfer pricing adjustment under s.92 required correct segmentation where the tax authority had aggregated marketing support/indenting and spare parts trading (AMC) as a single segment. The Tribunal held benchmarking must be performed separately for the two segments as presented by the taxpayer; the TPO must re-examine comparables and verify whether the taxpayer's results fall within the tolerance range under the proviso to s.92C(2), and the ALP determination was remanded. On non-compete fee, in light of the latest binding precedent, it was held to be revenue in nature; the AO was directed to treat it accordingly and to recompute consequential depreciation impact already claimed with the taxpayer's assistance - ITAT
Transfer pricing adjustment under s.92 required correct segmentation where the tax authority had aggregated marketing support/indenting and spare parts trading (AMC) as a single segment. The Tribunal held benchmarking must be performed separately for the two segments as presented by the taxpayer; the TPO must re-examine comparables and verify whether the taxpayer's results fall within the tolerance range under the proviso to s.92C(2), and the ALP determination was remanded. On non-compete fee, in light of the latest binding precedent, it was held to be revenue in nature; the AO was directed to treat it accordingly and to recompute consequential depreciation impact already claimed with the taxpayer's assistance - ITAT
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