Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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Transactions with a wholly owned pass-through foreign LLC, whose profits were already taxed in India, were treated as self-dealing rather than separate AE dealings, so no arm's length adjustment survived and the sale adjustment was deleted. Receivables from that same entity were held intrinsically linked to the underlying sales, so the separate interest adjustment was also deleted. For specified domestic transactions, the altered TNMM filters and reduced comparables were found unjustified; the eligible unit's margin fell within the existing range, so the recomputation of profits and related deduction reduction were deleted. The standalone challenge to initiation of penalty proceedings was dismissed as premature.
Transactions with a wholly owned pass-through foreign LLC, whose profits were already taxed in India, were treated as self-dealing rather than separate AE dealings, so no arm's length adjustment survived and the sale adjustment was deleted. Receivables from that same entity were held intrinsically linked to the underlying sales, so the separate interest adjustment was also deleted. For specified domestic transactions, the altered TNMM filters and reduced comparables were found unjustified; the eligible unit's margin fell within the existing range, so the recomputation of profits and related deduction reduction were deleted. The standalone challenge to initiation of penalty proceedings was dismissed as premature.
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