Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
In a transfer pricing dispute over specified domestic transactions for purchase of potatoes from an associated enterprise, the Tribunal held that the earlier coordinate bench ruling in the assessee's own case for the preceding year governed the issue on identical facts. Applying judicial discipline, it rejected the DRP's attempt to keep the matter open for the Revenue and found that CUP was not the most appropriate method. TNMM was upheld as the appropriate arm's length method, so the transfer pricing adjustment based on CUP was deleted. As the substantive addition did not survive, the consequential penalty proceedings for alleged under-reporting or misreporting under section 270A were rendered infructuous.
In a transfer pricing dispute over specified domestic transactions for purchase of potatoes from an associated enterprise, the Tribunal held that the earlier coordinate bench ruling in the assessee's own case for the preceding year governed the issue on identical facts. Applying judicial discipline, it rejected the DRP's attempt to keep the matter open for the Revenue and found that CUP was not the most appropriate method. TNMM was upheld as the appropriate arm's length method, so the transfer pricing adjustment based on CUP was deleted. As the substantive addition did not survive, the consequential penalty proceedings for alleged under-reporting or misreporting under section 270A were rendered infructuous.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
