Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
The article addresses transfer pricing adjustments for NCDs, applying the comparability filter to exclude specified opening NCDs from ALP adjustment and directing that the NCD with 13.20% coupon be benchmarked afresh using the Internal Comparable Uncontrolled Price as the most appropriate method after the assessee had furnished a benchmarking submission. It also holds that an appellate authority may admit a fresh deduction claim for customer incentives and remits quantification to the assessing officer for de novo adjudication. The assessing officer is directed to grant statutory interest on any refund in accordance with law.
The article addresses transfer pricing adjustments for NCDs, applying the comparability filter to exclude specified opening NCDs from ALP adjustment and directing that the NCD with 13.20% coupon be benchmarked afresh using the Internal Comparable Uncontrolled Price as the most appropriate method after the assessee had furnished a benchmarking submission. It also holds that an appellate authority may admit a fresh deduction claim for customer incentives and remits quantification to the assessing officer for de novo adjudication. The assessing officer is directed to grant statutory interest on any refund in accordance with law.
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