Country of Origin Certificates and declared transaction value supported preferential customs exemption where authenticity and invoice prices remained ...
Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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Certified segmental financials used in transfer pricing documentation could not be rejected merely for differing from AS-17 audited segment disclosure where the assessee explained the allocation method and no specific defect was found; the issue was remitted for fresh consideration. ECB interest at LIBOR plus 3% was held to be at arm's length because the borrowing had RBI approval and the TPO made only ad hoc substitution without proper comparability analysis. Outstanding receivables from AEs were treated as an international transaction, and interest was directed to be recomputed invoice-to-invoice at LIBOR plus 200 basis points in line with earlier years. The direction to verify brought-forward amalgamation losses and allow them according to law was upheld.
Certified segmental financials used in transfer pricing documentation could not be rejected merely for differing from AS-17 audited segment disclosure where the assessee explained the allocation method and no specific defect was found; the issue was remitted for fresh consideration. ECB interest at LIBOR plus 3% was held to be at arm's length because the borrowing had RBI approval and the TPO made only ad hoc substitution without proper comparability analysis. Outstanding receivables from AEs were treated as an international transaction, and interest was directed to be recomputed invoice-to-invoice at LIBOR plus 200 basis points in line with earlier years. The direction to verify brought-forward amalgamation losses and allow them according to law was upheld.
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