Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credi...
Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
In transfer pricing benchmarking, the turnover filter and broad functional comparability were treated as relevant comparability criteria under TNMM. A diagnostics company was validly excluded because its turnover fell below the modified range, and earlier-year inclusion did not control since each year must be tested on its own facts. A separate glassware and laboratory-products company was also excluded because its product mix and customer profile were not broadly comparable to medical devices used in patient treatment. Subvention receipts under the distribution arrangement were held to reduce operating cost, not form part of operating revenue, so the assessee's operating margin was correctly taken at 5.04%.
In transfer pricing benchmarking, the turnover filter and broad functional comparability were treated as relevant comparability criteria under TNMM. A diagnostics company was validly excluded because its turnover fell below the modified range, and earlier-year inclusion did not control since each year must be tested on its own facts. A separate glassware and laboratory-products company was also excluded because its product mix and customer profile were not broadly comparable to medical devices used in patient treatment. Subvention receipts under the distribution arrangement were held to reduce operating cost, not form part of operating revenue, so the assessee's operating margin was correctly taken at 5.04%.
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