Deferred Payment of Customs Duty extended to Eligible Manufacturer Importers with electronic registration and ICEGATE authentication for conditional c...
Tariff classification determines GST schedule and rate; beverages in Schedule III attract the higher rate, tea extracts and syrups in Schedule I attra...
Fraudulent trading requires cogent evidence of intent to defraud; ordinary-course payments protected, except post-insolvency withdrawals must be resto...
Transfer pricing adjustments on corporate guarantee commission and interest on convertible loans were rejected because identical issues were previously decided in favour of the taxpayer by the ITAT; outcome: adjustments deleted. Reimbursement of expenses was held at arm's length on documentary proof and past ITAT precedent; outcome: adjustment denied. Sale of goods to an AE benchmarked using Compustat North America fell within the 3% safe harbour margin and the adjustment was dismissed. Three rejected comparables were accepted as functionally and jurisdictionally comparable; outcome: AO/TPO rejection overturned. DIANE database search for a later year failed Rule 10CA requirements; outcome: comparable search rejected. Claim for weighted R&D deduction limited to expenditure approved by the competent authority was upheld; outcome: deduction restricted to DSIR-approved quantum.
Transfer pricing adjustments on corporate guarantee commission and interest on convertible loans were rejected because identical issues were previously decided in favour of the taxpayer by the ITAT; outcome: adjustments deleted. Reimbursement of expenses was held at arm's length on documentary proof and past ITAT precedent; outcome: adjustment denied. Sale of goods to an AE benchmarked using Compustat North America fell within the 3% safe harbour margin and the adjustment was dismissed. Three rejected comparables were accepted as functionally and jurisdictionally comparable; outcome: AO/TPO rejection overturned. DIANE database search for a later year failed Rule 10CA requirements; outcome: comparable search rejected. Claim for weighted R&D deduction limited to expenditure approved by the competent authority was upheld; outcome: deduction restricted to DSIR-approved quantum.
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