Prohibited importation of cosmetics without prior regulatory registration attracts seizure and confiscation; warehousing or re export claims do not cu...
Provisional release on security permitted where cash deposit plus bond secures differential duty; classification and treaty benefits referred for deci...
Customs Valuation Rule Sequence must be followed; single-comparator re-determination and penalties set aside without comparability or proof of mis-dec...
Separately Identifiable Services: transportation found to be the essential character, so Cargo Handling classification and extended limitation rejecte...
Transfer pricing dispute over use of TNMM: tribunal excluded specified comparables (Eclerx Services, Infosys BPO, Accentia) due to functional dissimilarity, directing AO/TPO to revise comparable set. Deduction claims under Section 10A: UB Plaza unit allowed as change of ownership by slump sale does not by itself defeat eligibility (CBDT Circular No.1/2013 noted); Titanium STPI unit remitted to AO for fresh factual and documentary verification and allocation of eligible profits if treated as expansion; STPI unit acquired from Reuters to be allowed. Claims on goodwill depreciation remitted for de novo AO verification; depreciation on software not hit by withholding provisions as it is an allowance, not revenue expenditure.
Transfer pricing dispute over use of TNMM: tribunal excluded specified comparables (Eclerx Services, Infosys BPO, Accentia) due to functional dissimilarity, directing AO/TPO to revise comparable set. Deduction claims under Section 10A: UB Plaza unit allowed as change of ownership by slump sale does not by itself defeat eligibility (CBDT Circular No.1/2013 noted); Titanium STPI unit remitted to AO for fresh factual and documentary verification and allocation of eligible profits if treated as expansion; STPI unit acquired from Reuters to be allowed. Claims on goodwill depreciation remitted for de novo AO verification; depreciation on software not hit by withholding provisions as it is an allowance, not revenue expenditure.
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