Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
