Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Personal hearing requirements in GST adjudication were satisfied by prior opportunities and written submissions; appellate limitation received writ-pe...
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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