Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
Integrated international transactions forming a single chain of product design, validation, manufacturing and sale were held to be benchmarkable under aggregated TNMM, and selective segregation of management, testing and validation services was rejected because the assessee's operating margin exceeded the comparable mean. The Transfer Pricing Officer could not fix arm's length price at nil without applying a recognised method, especially where records showed actual rendition of services. Outstanding receivables were treated as closely linked to the principal transaction and not separately benchmarked; with working capital adjustment already allowed and the assessee being debt-free, no notional interest adjustment survived. The appeal was allowed and the transfer pricing additions were deleted.
Integrated international transactions forming a single chain of product design, validation, manufacturing and sale were held to be benchmarkable under aggregated TNMM, and selective segregation of management, testing and validation services was rejected because the assessee's operating margin exceeded the comparable mean. The Transfer Pricing Officer could not fix arm's length price at nil without applying a recognised method, especially where records showed actual rendition of services. Outstanding receivables were treated as closely linked to the principal transaction and not separately benchmarked; with working capital adjustment already allowed and the assessee being debt-free, no notional interest adjustment survived. The appeal was allowed and the transfer pricing additions were deleted.
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