Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
For specified domestic transactions, market value constitutes the arm's length price, with the special rule in the Explanation to section 80A(6) prevailing over the general provision. Regulated tariffs at which generating companies supply distribution licensees are not comparable uncontrolled prices because they are not negotiated in uncontrolled conditions. The cement unit's purchase rate from its distribution licensee was the more reliable internal comparable for captive electricity transfers; functional differences did not alter that comparison, and a mark-up on an average price was unsustainable. The transfer-pricing adjustment was deleted and the related deduction allowed. A challenge solely to initiation of penalty proceedings was dismissed as premature.
For specified domestic transactions, market value constitutes the arm's length price, with the special rule in the Explanation to section 80A(6) prevailing over the general provision. Regulated tariffs at which generating companies supply distribution licensees are not comparable uncontrolled prices because they are not negotiated in uncontrolled conditions. The cement unit's purchase rate from its distribution licensee was the more reliable internal comparable for captive electricity transfers; functional differences did not alter that comparison, and a mark-up on an average price was unsustainable. The transfer-pricing adjustment was deleted and the related deduction allowed. A challenge solely to initiation of penalty proceedings was dismissed as premature.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
