Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
Where a dependent agent permanent establishment in India has already been remunerated at arm's length, no further profits are attributable to that permanent establishment. Applying Morgan Stanley and Honda Motors, the ITAT held that the AO's ad hoc attribution of revenue and estimation of profit under Rule 10 was unjustified because the transfer pricing study had been furnished and the arm's length nature of the transactions was neither adversely examined nor doubted. The addition for further profit attribution was deleted, and the remaining grounds were treated as academic.
Where a dependent agent permanent establishment in India has already been remunerated at arm's length, no further profits are attributable to that permanent establishment. Applying Morgan Stanley and Honda Motors, the ITAT held that the AO's ad hoc attribution of revenue and estimation of profit under Rule 10 was unjustified because the transfer pricing study had been furnished and the arm's length nature of the transactions was neither adversely examined nor doubted. The addition for further profit attribution was deleted, and the remaining grounds were treated as academic.
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