Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Appointment of Registrars as adjudicating officers under Companies Act reallocates territorial jurisdiction and sets appeal route to Regional Director...
Composite supply of drilling services and site specific chemicals characterised as composite supply; prior advance rulings set aside, tax rate left op...
Cross country pipeline classification and ITC entitlement: pipelines outside factory treated as immovable, ITC disallowed under Section 17 restriction...
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Transfer pricing adjustments challenged: internal Comparable Uncontrolled Price benchmarking for interest on loans to associated enterprises upheld and ad hoc 100 basis point forex risk addition rejected, resulting in deletion of the upward interest adjustment. Notional interest on overdue receivables treated as part of the principal international sale transaction and deleted. Depreciation claim on goodwill arising from amalgamation sustained for lack of commercial substance challenge. Allocation of common expenses to incentivised units accepted where supported by separate books. Weighted deduction under research provisions not confined to the amount in approval form. Disallowances under interest allocation and Rule 8D deleted; commission to non resident agents not taxable in India absent business connection.
Transfer pricing adjustments challenged: internal Comparable Uncontrolled Price benchmarking for interest on loans to associated enterprises upheld and ad hoc 100 basis point forex risk addition rejected, resulting in deletion of the upward interest adjustment. Notional interest on overdue receivables treated as part of the principal international sale transaction and deleted. Depreciation claim on goodwill arising from amalgamation sustained for lack of commercial substance challenge. Allocation of common expenses to incentivised units accepted where supported by separate books. Weighted deduction under research provisions not confined to the amount in approval form. Disallowances under interest allocation and Rule 8D deleted; commission to non resident agents not taxable in India absent business connection.
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