Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof...
Management support services supported by agreements, invoices, allocation records, presentations, e-mails and time sheets were treated as genuine business services, not mere stewardship or shareholder activities, so the arm's length price could not be fixed at nil without applying a recognised transfer pricing method. In the manufacturing segment, TNMM analysis showed the tested party's operating margin remained higher than the corrected comparable margin, so no transfer pricing adjustment could survive. The appellate deletion of both adjustments was sustained.
Management support services supported by agreements, invoices, allocation records, presentations, e-mails and time sheets were treated as genuine business services, not mere stewardship or shareholder activities, so the arm's length price could not be fixed at nil without applying a recognised transfer pricing method. In the manufacturing segment, TNMM analysis showed the tested party's operating margin remained higher than the corrected comparable margin, so no transfer pricing adjustment could survive. The appellate deletion of both adjustments was sustained.
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