Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
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In transfer pricing benchmarking for contract R&D support services, the Tribunal held that the expression "persistent loss-making" could not exclude comparables that had losses only in earlier years but profits in the year under review; Micro Therapeutic Research Labs Ltd. and Choksi Laboratories Ltd. were therefore to be retained as comparables. It also held that quantitative turnover filters may be relaxed pragmatically where deviation is marginal and functional comparability is otherwise undisputed; Micro Therapeutic Research Labs Ltd. was included despite exceeding the upper threshold only slightly. On inclusion of these comparables, the assessee's margin was found to be within the arm's length range, so the transfer pricing adjustment was deleted. Interest was consequential and initiation of penalty was premature.
In transfer pricing benchmarking for contract R&D support services, the Tribunal held that the expression "persistent loss-making" could not exclude comparables that had losses only in earlier years but profits in the year under review; Micro Therapeutic Research Labs Ltd. and Choksi Laboratories Ltd. were therefore to be retained as comparables. It also held that quantitative turnover filters may be relaxed pragmatically where deviation is marginal and functional comparability is otherwise undisputed; Micro Therapeutic Research Labs Ltd. was included despite exceeding the upper threshold only slightly. On inclusion of these comparables, the assessee's margin was found to be within the arm's length range, so the transfer pricing adjustment was deleted. Interest was consequential and initiation of penalty was premature.
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