Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Reassessment against a deceased assessee: procedural defect mandates fresh reassessment; nonresponsive petitioner may be treated as legal representati...
Transfer pricing controversy turned on the correct characterization of transactions between an LLP and its associated enterprise, the proper appreciation of their FAR profiles, and the resulting arm's length pricing analysis. The Tribunal noted that the revenue authorities had relied on assumptions about the entities' activities and risk allocation, while the assessee's claim of cost-to-cost reimbursement had not been tested against complete contemporaneous material, including financials, employee profile, contractual terms and risk assumption. It held that the basis for applying the Profit Split Method was insufficiently reasoned and required fresh examination. The assessment and DRP-backed adjustment were set aside and the matter was restored to the AO/TPO for de novo adjudication and a speaking order.
Transfer pricing controversy turned on the correct characterization of transactions between an LLP and its associated enterprise, the proper appreciation of their FAR profiles, and the resulting arm's length pricing analysis. The Tribunal noted that the revenue authorities had relied on assumptions about the entities' activities and risk allocation, while the assessee's claim of cost-to-cost reimbursement had not been tested against complete contemporaneous material, including financials, employee profile, contractual terms and risk assumption. It held that the basis for applying the Profit Split Method was insufficiently reasoned and required fresh examination. The assessment and DRP-backed adjustment were set aside and the matter was restored to the AO/TPO for de novo adjudication and a speaking order.
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