Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Reassessment against a deceased assessee: procedural defect mandates fresh reassessment; nonresponsive petitioner may be treated as legal representati...
Transfer pricing adjustment on overdue receivables was upheld only in principle, but recomputation was ordered on the basis of a 90-day credit period, verification of comparable credit terms, correction of receipt dates, and fresh benchmarking of the arm's length interest rate through proper FAR analysis. The plea that no interest could be imputed to a debt-free entity was rejected, and the working capital adjustment argument failed because no such adjustment had been claimed in the transfer pricing study. The Tribunal also directed deletion of the double addition for foreign exchange loss, correction of the mismatch between assessed income and the computation sheet, and grant of TDS and foreign tax credit. Interest under section 234A was deleted because the return was filed within the extended due date.
Transfer pricing adjustment on overdue receivables was upheld only in principle, but recomputation was ordered on the basis of a 90-day credit period, verification of comparable credit terms, correction of receipt dates, and fresh benchmarking of the arm's length interest rate through proper FAR analysis. The plea that no interest could be imputed to a debt-free entity was rejected, and the working capital adjustment argument failed because no such adjustment had been claimed in the transfer pricing study. The Tribunal also directed deletion of the double addition for foreign exchange loss, correction of the mismatch between assessed income and the computation sheet, and grant of TDS and foreign tax credit. Interest under section 234A was deleted because the return was filed within the extended due date.
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