Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
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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