Prohibited importation of cosmetics without prior regulatory registration attracts seizure and confiscation; warehousing or re export claims do not cu...
Provisional release on security permitted where cash deposit plus bond secures differential duty; classification and treaty benefits referred for deci...
Customs Valuation Rule Sequence must be followed; single-comparator re-determination and penalties set aside without comparability or proof of mis-dec...
Separately Identifiable Services: transportation found to be the essential character, so Cargo Handling classification and extended limitation rejecte...
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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