Classification of imported salvaged shaft pieces as ship parts confirmed, reassessment time-barred and appeal allowed restoring original classificatio...
Scope of intermediary status for data hosting services: tribunal finds provider not intermediary, services exported and not taxable, limited remand on...
CENVAT credit availability after omission of Rule 12B in textiles confirmed; late addendum to SCN introducing new grounds held time-barred and invalid...
Export of Wheat Flour and related products subject to online allocation, eligibility criteria, non-transferable six-month authorisations and reporting...
Business and management consultancy charges closely linked to the assessee's operations were held to be benchmarked on an aggregated basis under TNMM, not by a separate ALP analysis, where receipt of services was supported by additional evidence; the matter was remitted for fresh examination by the TPO after considering that evidence. For outstanding receivables from the associated enterprise, the Tribunal applied average LIBOR as the appropriate benchmark rate for delayed payment interest, rejecting the ad hoc higher rate adopted by the lower authorities. The appeal was partly allowed, with consultancy charges sent back for recomputation and receivable interest directed to be recalculated using average LIBOR.
Business and management consultancy charges closely linked to the assessee's operations were held to be benchmarked on an aggregated basis under TNMM, not by a separate ALP analysis, where receipt of services was supported by additional evidence; the matter was remitted for fresh examination by the TPO after considering that evidence. For outstanding receivables from the associated enterprise, the Tribunal applied average LIBOR as the appropriate benchmark rate for delayed payment interest, rejecting the ad hoc higher rate adopted by the lower authorities. The appeal was partly allowed, with consultancy charges sent back for recomputation and receivable interest directed to be recalculated using average LIBOR.
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