Prohibited importation of cosmetics without prior regulatory registration attracts seizure and confiscation; warehousing or re export claims do not cu...
Provisional release on security permitted where cash deposit plus bond secures differential duty; classification and treaty benefits referred for deci...
Customs Valuation Rule Sequence must be followed; single-comparator re-determination and penalties set aside without comparability or proof of mis-dec...
Separately Identifiable Services: transportation found to be the essential character, so Cargo Handling classification and extended limitation rejecte...
Transfer pricing on back-to-back project execution was held to be benchmarked under the CUP method rather than TNMM because the assessee acted as a project office for the foreign principal and the relevant transactions were direct services to the associated enterprise. The Tribunal treated the joint venture structure as an administrative vehicle, noted that the project results and related financials were already recorded and taxed in India, and found no realistic profit-shifting concern where the operations and reimbursements were domestic in nature. On that basis, it affirmed deletion of the transfer pricing adjustment and rejected the Revenue's challenge.
Transfer pricing on back-to-back project execution was held to be benchmarked under the CUP method rather than TNMM because the assessee acted as a project office for the foreign principal and the relevant transactions were direct services to the associated enterprise. The Tribunal treated the joint venture structure as an administrative vehicle, noted that the project results and related financials were already recorded and taxed in India, and found no realistic profit-shifting concern where the operations and reimbursements were domestic in nature. On that basis, it affirmed deletion of the transfer pricing adjustment and rejected the Revenue's challenge.
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