International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
Recurring transfer pricing and TDS disputes were decided largely by following the Tribunal's earlier orders in the assessee's own case. AMP adjustment and alleged short charge to the associated enterprise were not disturbed, advertisement and publicity expenditure was held revenue in nature despite an asserted enduring benefit, payment gateway charges were not disallowed for want of TDS, deferred contract receipts were not taxed as accrued income for the unexpired period, reimbursement of ticketing cost to MMT US was held outside section 195 because it was not taxable in India, and ESOP expenditure was treated as allowable employee compensation. Higher depreciation on computer peripherals was rejected.
Recurring transfer pricing and TDS disputes were decided largely by following the Tribunal's earlier orders in the assessee's own case. AMP adjustment and alleged short charge to the associated enterprise were not disturbed, advertisement and publicity expenditure was held revenue in nature despite an asserted enduring benefit, payment gateway charges were not disallowed for want of TDS, deferred contract receipts were not taxed as accrued income for the unexpired period, reimbursement of ticketing cost to MMT US was held outside section 195 because it was not taxable in India, and ESOP expenditure was treated as allowable employee compensation. Higher depreciation on computer peripherals was rejected.
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