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 ...
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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