Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
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Transfer pricing dispute over benchmarking of AMP expenses and appropriate ALP method: the Bright Line Test (BLT) adjustments are held legally unsustainable and deleted; the Cost Plus method is rejected as unjustified because the assessee acted as a distributor incurring routine business promotion and employee costs that should form part of trading cost; the tribunal accepts comparability under adjusted TNMM and directs an ALP uplift equal to the difference between the comparable PLI and the assessee's margin, instructing the AO to compute and apply that limited adjustment in line with the cited Sony Ericsson precedent.
Transfer pricing dispute over benchmarking of AMP expenses and appropriate ALP method: the Bright Line Test (BLT) adjustments are held legally unsustainable and deleted; the Cost Plus method is rejected as unjustified because the assessee acted as a distributor incurring routine business promotion and employee costs that should form part of trading cost; the tribunal accepts comparability under adjusted TNMM and directs an ALP uplift equal to the difference between the comparable PLI and the assessee's margin, instructing the AO to compute and apply that limited adjustment in line with the cited Sony Ericsson precedent.
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