Goods Transport Agency services via e commerce portals: consignment note creates custody and liability and enables exemption for unregistered recipien...
Reverse charge and assignment of royalty collection: exemption for excess royalty collectors subject to reconciliation; leaseholders remain liable und...
In transfer pricing, broad functional comparability under TNMM was applied: Bright Brothers Ltd. was retained because product differences did not matter where functions were broadly similar, and REIL Electricals India Ltd. was included as functionally similar. Working capital adjustment was treated as a valid claim and was directed to be allowed, subject to the assessee furnishing supporting details and data. On royalty, technical know-how and technical services, the Tribunal upheld deletion of the adjustment because CUP was adopted without comparable uncontrolled data and the principle of consistency supported the assessee, as no adjustment had been made in earlier or subsequent years on the same agreements.
In transfer pricing, broad functional comparability under TNMM was applied: Bright Brothers Ltd. was retained because product differences did not matter where functions were broadly similar, and REIL Electricals India Ltd. was included as functionally similar. Working capital adjustment was treated as a valid claim and was directed to be allowed, subject to the assessee furnishing supporting details and data. On royalty, technical know-how and technical services, the Tribunal upheld deletion of the adjustment because CUP was adopted without comparable uncontrolled data and the principle of consistency supported the assessee, as no adjustment had been made in earlier or subsequent years on the same agreements.
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