Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Transaction value declared for imports from a related foreign principal was held to represent true assessable value because the supervisory valuation bench had concluded the relationship did not influence price; the assessing officers rejection based on later observations and selected contemporaneous third-party prices was unjustified. The tribunal found the SVB order valid for the relevant consignments, disapproved adoption of third-party contemporaneous prices where buyers and quantities differed, and accepted that price differences fell within permissible resale margins and overheads. Consequentially, the impugned re-determination of value was set aside and the appeal allowed.
Transaction value declared for imports from a related foreign principal was held to represent true assessable value because the supervisory valuation bench had concluded the relationship did not influence price; the assessing officers rejection based on later observations and selected contemporaneous third-party prices was unjustified. The tribunal found the SVB order valid for the relevant consignments, disapproved adoption of third-party contemporaneous prices where buyers and quantities differed, and accepted that price differences fell within permissible resale margins and overheads. Consequentially, the impugned re-determination of value was set aside and the appeal allowed.
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