Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof...
Tribunal held that clause (i) of the statutory provision defining specified domestic transactions was omitted with retrospective effect, applying established precedent on retrospective omission so the provision is treated as never having existed; consequently references to the Transfer Pricing Officer and transfer pricing adjustments for the relevant assessment year were invalid and the additions based solely on that provision were directed to be deleted, leading to allowance of the appeal and removal of the contested additions.
Tribunal held that clause (i) of the statutory provision defining specified domestic transactions was omitted with retrospective effect, applying established precedent on retrospective omission so the provision is treated as never having existed; consequently references to the Transfer Pricing Officer and transfer pricing adjustments for the relevant assessment year were invalid and the additions based solely on that provision were directed to be deleted, leading to allowance of the appeal and removal of the contested additions.
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