Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Dividend distribution tax on payments to a non-resident shareholder was examined against the India-Netherlands DTAA, with the Tribunal noting that treaty rate restriction may apply and that the matter required verification of the applicable treaty and domestic rate comparison; the issue was remitted to the Assessing Officer for fresh adjudication after due examination. Transfer pricing adjustment on management fees was also sent back for fresh consideration because the assessee's cost-benefit material and the benchmarking approach, including aggregation, had not been fully examined; the Dispute Resolution Panel was directed to reconsider the issue with adequate opportunity to the assessee.
Dividend distribution tax on payments to a non-resident shareholder was examined against the India-Netherlands DTAA, with the Tribunal noting that treaty rate restriction may apply and that the matter required verification of the applicable treaty and domestic rate comparison; the issue was remitted to the Assessing Officer for fresh adjudication after due examination. Transfer pricing adjustment on management fees was also sent back for fresh consideration because the assessee's cost-benefit material and the benchmarking approach, including aggregation, had not been fully examined; the Dispute Resolution Panel was directed to reconsider the issue with adequate opportunity to the assessee.
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