Admissibility of electronic evidence bars undervaluation demands where printouts, retracted statements and no cross-examination leave the case unprove...
Limitation in oppression and mismanagement proceedings: prior knowledge of removal and dilution barred the challenge, with valuation directions upheld...
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Where transfer pricing analysis was applied uniformly to all international transactions and no separate benchmarking was carried out for non-US based AE transactions, the Tribunal treated the BAPA margin as a reliable persuasive benchmark. It noted that the Revenue failed to show any material difference in the FAR profile of the non-US transactions from those covered by the BAPA. Applying the principle of consistency, the Tribunal accepted the assessee's claim and directed adoption of the BAPA margin for determining the arm's length price of the non-US based AE transactions as well. The appeals were allowed.
Where transfer pricing analysis was applied uniformly to all international transactions and no separate benchmarking was carried out for non-US based AE transactions, the Tribunal treated the BAPA margin as a reliable persuasive benchmark. It noted that the Revenue failed to show any material difference in the FAR profile of the non-US transactions from those covered by the BAPA. Applying the principle of consistency, the Tribunal accepted the assessee's claim and directed adoption of the BAPA margin for determining the arm's length price of the non-US based AE transactions as well. The appeals were allowed.
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