Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
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...
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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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