Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
Transfer pricing assessment addressed comparability and benchmarking: TNMM comparables were adjusted where functional dissimilarity, related-party transactions filter and high outsourcing materially affected arm's length pricing, with a limited remand to verify exclusion of one comparable; five previously rejected comparables are to be included. Guarantee commission was benchmarked by CUP but accepted on an allocation reflecting the assessee's FAR and back-to-back risk allocation, deleting the upward adjustment. TDS liability under section 195/40(a)(i) judged by law at payment date; payments to foreign card networks were not taxable in India and disallowance deleted. Prior-year taxation settled under Vivad se Vishwas adjusted to avoid double taxation.
Transfer pricing assessment addressed comparability and benchmarking: TNMM comparables were adjusted where functional dissimilarity, related-party transactions filter and high outsourcing materially affected arm's length pricing, with a limited remand to verify exclusion of one comparable; five previously rejected comparables are to be included. Guarantee commission was benchmarked by CUP but accepted on an allocation reflecting the assessee's FAR and back-to-back risk allocation, deleting the upward adjustment. TDS liability under section 195/40(a)(i) judged by law at payment date; payments to foreign card networks were not taxable in India and disallowance deleted. Prior-year taxation settled under Vivad se Vishwas adjusted to avoid double taxation.
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