Deferred Payment of Customs Duty extended to Eligible Manufacturer Importers with electronic registration and ICEGATE authentication for conditional c...
Tariff classification determines GST schedule and rate; beverages in Schedule III attract the higher rate, tea extracts and syrups in Schedule I attra...
Fraudulent trading requires cogent evidence of intent to defraud; ordinary-course payments protected, except post-insolvency withdrawals must be resto...
ITAT held that back-to-back guarantee processing fees were correctly benchmarked under TNMM, because the assessee acted only as an administrative intermediary and did not bear the invocation risk; bank guarantee rates from third parties were not comparable, so the transfer-pricing adjustment was deleted. For derivative-related marketing support services, the Tribunal rejected PSM based on day-end NPV because the transactions were back-to-back, the assessee bore no trading risk, and aggregation of closely linked transactions left no surviving adjustment. It also held that telecommunication and expatriate personnel costs incurred exclusively for the Indian branch were direct branch expenses, not common administrative , so section 44C disallowance failed. Interest paid by the branch to head office or overseas branches remained a payment to self and was not taxable for the year in issue.
ITAT held that back-to-back guarantee processing fees were correctly benchmarked under TNMM, because the assessee acted only as an administrative intermediary and did not bear the invocation risk; bank guarantee rates from third parties were not comparable, so the transfer-pricing adjustment was deleted. For derivative-related marketing support services, the Tribunal rejected PSM based on day-end NPV because the transactions were back-to-back, the assessee bore no trading risk, and aggregation of closely linked transactions left no surviving adjustment. It also held that telecommunication and expatriate personnel costs incurred exclusively for the Indian branch were direct branch expenses, not common administrative , so section 44C disallowance failed. Interest paid by the branch to head office or overseas branches remained a payment to self and was not taxable for the year in issue.
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