Authentication of paper assessment orders upheld, while qualifying repairs, consumables and vendor advance write-offs remain deductible business claim...
Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
Cross-examination rights and corroborated evidence limit customs penalties for misdeclaration in genuine import transactions involving documented clea...
Tariff classification of vehicle gear components follows the specific gearing entry, displacing motor-vehicle parts classification and related liabili...
Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
ITAT held that remeasurement gain on defined employee benefit plans is an operating item for TNMM because it stems from the employer-employee cost structure and not from financing or investment activity, and the AO/TPO had to recompute the PLI accordingly. In selecting comparables, the Tribunal upheld inclusion or exclusion based on functional similarity, segmental data and RPT filters, while persistent loss treatment was accepted where applied consistently. It further held that transfer pricing adjustment must be restricted to international transactions with AEs, not domestic non-AE turnover. Interest on overdue receivables was to be benchmarked separately at LIBOR plus 200 basis points after a 30-day credit period, nil ALP for intra-group service charges was deleted, and credit for advance tax and TDS was remanded for verification.
ITAT held that remeasurement gain on defined employee benefit plans is an operating item for TNMM because it stems from the employer-employee cost structure and not from financing or investment activity, and the AO/TPO had to recompute the PLI accordingly. In selecting comparables, the Tribunal upheld inclusion or exclusion based on functional similarity, segmental data and RPT filters, while persistent loss treatment was accepted where applied consistently. It further held that transfer pricing adjustment must be restricted to international transactions with AEs, not domestic non-AE turnover. Interest on overdue receivables was to be benchmarked separately at LIBOR plus 200 basis points after a 30-day credit period, nil ALP for intra-group service charges was deleted, and credit for advance tax and TDS was remanded for verification.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4821 
Join Channel 
