Courier transshipment of imported goods via named carrier to air cargo stations renewed until 30.01.2026; exemption conditional, strict controls apply...
Insurer's investment gains and investment write-downs face Section 263 revision; enquiry upheld, Rule 5(b)(ii) lapse sustained, late corrigendum quash...
Transfer pricing adjustment arising from royalty payments requires benchmarking by the most appropriate traditional transaction method; where exact identical comparables exist the CUP method should be applied, but selected comparables must be functionally comparable and not mere local manufacturers or brand developers. The impugned comparables were held inappropriate and the matter is remitted to AO/TPO to re-benchmark afresh after affording the assessee hearing and considering the submitted TPAR; if no exact comparables receiving bundled services are found, benchmarking should proceed under TNMM using proper comparables.
Transfer pricing adjustment arising from royalty payments requires benchmarking by the most appropriate traditional transaction method; where exact identical comparables exist the CUP method should be applied, but selected comparables must be functionally comparable and not mere local manufacturers or brand developers. The impugned comparables were held inappropriate and the matter is remitted to AO/TPO to re-benchmark afresh after affording the assessee hearing and considering the submitted TPAR; if no exact comparables receiving bundled services are found, benchmarking should proceed under TNMM using proper comparables.
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