Disciplinary proportionality requires penalties for Authorised Representative misconduct to match proven harm, leading to reconsideration of registrat...
Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Royalty benchmarking for technical know-how requires reliable comparable uncontrolled transactions before applying the Comparable Uncontrolled Price method. Where royalty payments are interrelated with manufacturing and other international transactions, and no evidence establishes an independent royalty transaction or supports CUP comparables, entity-level aggregation under the Transactional Net Margin Method is appropriate; a benefit test alone cannot justify a nil arm's length price. Consistency also requires Revenue to follow an earlier transfer-pricing determination where the royalty agreement, rates, and material facts remain unchanged. The transfer-pricing adjustment on royalty payments was deleted and the Revenue's appeals were dismissed.
Royalty benchmarking for technical know-how requires reliable comparable uncontrolled transactions before applying the Comparable Uncontrolled Price method. Where royalty payments are interrelated with manufacturing and other international transactions, and no evidence establishes an independent royalty transaction or supports CUP comparables, entity-level aggregation under the Transactional Net Margin Method is appropriate; a benefit test alone cannot justify a nil arm's length price. Consistency also requires Revenue to follow an earlier transfer-pricing determination where the royalty agreement, rates, and material facts remain unchanged. The transfer-pricing adjustment on royalty payments was deleted and the Revenue's appeals were dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
