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 ...
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Adoption of CERC tariff for internal bagasse transfer was rejected because treating bagasse as a by product with captive consumption, cost analysis using FRP and third party quotations produced a more realistic arm's length price; the Tribunal directed acceptance of the assessee's Rs.1,500/ton transfer price. The write off of loans/advances to a wholly owned subsidiary was held to be a business loss incurred for commercial expediency and allowable under the law as a deduction under business loss provisions. Harvesting and transport payments were found not to attract withholding under contract withholding rules, so no disallowance under withholding non compliance was warranted. Dispute on interest deduction timing requires AO verification under payment timing rules.
Adoption of CERC tariff for internal bagasse transfer was rejected because treating bagasse as a by product with captive consumption, cost analysis using FRP and third party quotations produced a more realistic arm's length price; the Tribunal directed acceptance of the assessee's Rs.1,500/ton transfer price. The write off of loans/advances to a wholly owned subsidiary was held to be a business loss incurred for commercial expediency and allowable under the law as a deduction under business loss provisions. Harvesting and transport payments were found not to attract withholding under contract withholding rules, so no disallowance under withholding non compliance was warranted. Dispute on interest deduction timing requires AO verification under payment timing rules.
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