Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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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