Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The Tribunal held that its earlier provisional release order under Section 110A was an interim arrangement balancing both sides and had already contemplated movement of goods from an SEZ unit to another SEZ unit, an EOU, or the DTA, as well as return-linked adjustment of the bank guarantee. The contingency later projected by the applicant was therefore not an apparent mistake on the record, and the plea of possible double duty did not justify rectification. Any operational difficulty in applying the release conditions could only be addressed by clarification, not by review through a ROM application. The rectification request was dismissed, while the Tribunal directed expeditious completion of the investigation.
The Tribunal held that its earlier provisional release order under Section 110A was an interim arrangement balancing both sides and had already contemplated movement of goods from an SEZ unit to another SEZ unit, an EOU, or the DTA, as well as return-linked adjustment of the bank guarantee. The contingency later projected by the applicant was therefore not an apparent mistake on the record, and the plea of possible double duty did not justify rectification. Any operational difficulty in applying the release conditions could only be addressed by clarification, not by review through a ROM application. The rectification request was dismissed, while the Tribunal directed expeditious completion of the investigation.
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