Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Transfer pricing adjustments for sales to an associated enterprise were found unsustainable where abnormal business conditions followed the shutdown of the assessee's main customer, because benchmarking had to reflect the extraordinary circumstances and the actual downstream use of the goods. Business expenditure was treated as deductible going concern expenditure: the outlay was incurred to keep trading operations running, and an ad hoc disallowance based on assumed future expansion was rejected. A sale of plant and machinery was held to be an itemised asset sale, not a slump sale, because values were assigned asset-wise and there was no transfer of the undertaking as a whole.
Transfer pricing adjustments for sales to an associated enterprise were found unsustainable where abnormal business conditions followed the shutdown of the assessee's main customer, because benchmarking had to reflect the extraordinary circumstances and the actual downstream use of the goods. Business expenditure was treated as deductible going concern expenditure: the outlay was incurred to keep trading operations running, and an ad hoc disallowance based on assumed future expansion was rejected. A sale of plant and machinery was held to be an itemised asset sale, not a slump sale, because values were assigned asset-wise and there was no transfer of the undertaking as a whole.
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