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 ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
Transfer pricing adjustment on interest paid on non-convertible debentures was deleted because the assessee had already added the interest to total income and paid tax, and further disallowance would cause impermissible double taxation. The tribunal rejected revenue's suggestion that the disallowed interest was carried forward, noting returns and audit reports showed no such claim. The assessee was held entitled to the concessional tax rate under 115BAA despite delayed filing of Form 10-IC, the delay deemed a procedural lapse and covered by pandemic time extensions. Interest under sections 234B and 234C to be computed as directed.
Transfer pricing adjustment on interest paid on non-convertible debentures was deleted because the assessee had already added the interest to total income and paid tax, and further disallowance would cause impermissible double taxation. The tribunal rejected revenue's suggestion that the disallowed interest was carried forward, noting returns and audit reports showed no such claim. The assessee was held entitled to the concessional tax rate under 115BAA despite delayed filing of Form 10-IC, the delay deemed a procedural lapse and covered by pandemic time extensions. Interest under sections 234B and 234C to be computed as directed.
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