Concessional Basic Customs Duty on Ethernet switches: classification as enterprise switches upheld, challenge dismissed for lack of substantial law qu...
Insolvency petition based on admitted debt and default upheld; challenge for malicious initiation rejected, settlement may proceed under resolution fr...
Quashing of FIR and challenge to ECIR over alleged diversion of funds and preferential ESOP pricing dismissed after prima facie money-laundering findi...
Transfer pricing dispute over benchmarking of a guarantee commission: the article explains that the tax authority applied an ad hoc upward adjustment using a CUP-based market rate, but a tribunal relied on earlier coordinate-bench analysis that the combined guarantee fee approximated 0.69% and the assessee's allocated share (about 57%) reflected limited functions, absence of independent risk-bearing, and a back-to-back counter guarantee; applying that reasoning the tribunal found the TPO/DRP ad hoc rate untenable and deleted the upward transfer pricing adjustment to the guarantee commission for the year under review.
Transfer pricing dispute over benchmarking of a guarantee commission: the article explains that the tax authority applied an ad hoc upward adjustment using a CUP-based market rate, but a tribunal relied on earlier coordinate-bench analysis that the combined guarantee fee approximated 0.69% and the assessee's allocated share (about 57%) reflected limited functions, absence of independent risk-bearing, and a back-to-back counter guarantee; applying that reasoning the tribunal found the TPO/DRP ad hoc rate untenable and deleted the upward transfer pricing adjustment to the guarantee commission for the year under review.
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