Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
Jurisdictional facts in certificate-of-origin discrepancies can support customs show-cause proceedings, leaving factual explanations for departmental ...
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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