https://www.taxtmi.com/caselaws?id=274874 The High Court determined that the appellant, a distributor, could not be classified as a manufacturer despite involvement in design and specifications. The Court directed further examination by tax authorities to establish the correct Arm's Length Price (ALP) for international transactions. It allowed for fresh adjudication on the method selection, considering statutory duty differences. The Court ruled in favor of the appellant, permitting a comprehensive reevaluation of factual aspects without constraints from prior decisions. The decision emphasized independent assessment of remanded matters, ensuring a fair review and favoring the appellant's position. en-us Wed, 20 Jul 2016 00:00:00 +0530 Sat, 08 Sep 2018 08:05:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=274874 The High Court determined that the appellant, a distributor, could not be classified as a manufacturer despite involvement in design and specifications. The Court directed further examination by tax authorities to establish the correct Arm's Length Price (ALP) for international transactions. It allowed for fresh adjudication on the method selection, considering statutory duty differences. The Court ruled in favor of the appellant, permitting a comprehensive reevaluation of factual aspects without constraints from prior decisions. The decision emphasized independent assessment of remanded matters, ensuring a fair review and favoring the appellant's position. Case-Laws Income Tax Wed, 20 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=274874