Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Royalty and technical-fee payments to an associated enterprise may be benchmarked by reference to a unilateral advance pricing agreement accepted by CBDT where its methodology is applicable; the payments were benchmarked at 1.9% of net sales rather than reduced to nil. Related-party manufacturing expenditure covered by section 40A(2)(b), once excluded from specified domestic transactions under section 92BA, cannot support a transfer-pricing adjustment. The manufacturing adjustment was therefore deleted, and the appeal was partly allowed.
Royalty and technical-fee payments to an associated enterprise may be benchmarked by reference to a unilateral advance pricing agreement accepted by CBDT where its methodology is applicable; the payments were benchmarked at 1.9% of net sales rather than reduced to nil. Related-party manufacturing expenditure covered by section 40A(2)(b), once excluded from specified domestic transactions under section 92BA, cannot support a transfer-pricing adjustment. The manufacturing adjustment was therefore deleted, and the appeal was partly allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4907 
