Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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