Misdeclaration of quantity rejected where supplier evidence established counting errors, so reassessment, confiscation and redemption fine were set as...
Admissibility of electronic evidence controls valuation and penalty exposure; non compliant e records and statements nullify revaluation and penalties...
Pure cost-to-cost reimbursements for IT infrastructure and software support, seconded employee salaries, and travel costs were treated as non-income items, not fees for technical, managerial, or consultancy services, so no withholding obligation arose and the related disallowances were deleted. On receivables, the text states that where the advance pricing agreement did not fix a specific date for applying prevailing LIBOR, the assessee's use of publicly available six-month USD LIBOR was accepted and the transfer pricing adjustment for delayed realisation of invoices was set aside.
Pure cost-to-cost reimbursements for IT infrastructure and software support, seconded employee salaries, and travel costs were treated as non-income items, not fees for technical, managerial, or consultancy services, so no withholding obligation arose and the related disallowances were deleted. On receivables, the text states that where the advance pricing agreement did not fix a specific date for applying prevailing LIBOR, the assessee's use of publicly available six-month USD LIBOR was accepted and the transfer pricing adjustment for delayed realisation of invoices was set aside.
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