Assessment time-barred u/s 153 due to missing competent-authority reference for Singapore exchange of information; assessment disallowed as barred by ...
Imported menthol-scented sweet supari classification dispute: seizure quashed, release for home consumption subject to duty bond; bank guarantee refus...
CKD/SKD air-conditioner components classifiable with finished units by essential character; prior advance ruling extended three years, FTA benefits po...
Transfer pricing adjustment challenged the use of differential commission rates by revenue authorities; the TPO/AO applied an ad hoc thumb rule without evidentiary comparables. Treating commission received as the arm's length price for benchmarking commission paid was held impermissible where transactions were not between uncontrolled parties or concluded on uncontrolled conditions. Consequently, the impugned addition was deleted. The AO is directed to give effect to this order and reassess and charge interest consequentially under the relevant tax provisions, and to verify the filing due date before considering interest under the return filing provision.
Transfer pricing adjustment challenged the use of differential commission rates by revenue authorities; the TPO/AO applied an ad hoc thumb rule without evidentiary comparables. Treating commission received as the arm's length price for benchmarking commission paid was held impermissible where transactions were not between uncontrolled parties or concluded on uncontrolled conditions. Consequently, the impugned addition was deleted. The AO is directed to give effect to this order and reassess and charge interest consequentially under the relevant tax provisions, and to verify the filing due date before considering interest under the return filing provision.
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