Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Under the combined transaction approach to TNMM, separate benchmarking of royalty and Global Accounts Manager charges is impermissible where those costs are already included in the operating costs of the logistics segment being benchmarked. The transfer pricing adjustments for those items were therefore deleted, consistent with the principle that individual cost elements embedded in an accepted combined segment analysis should not be separately benchmarked without a corresponding cost-base adjustment. Claims concerning TDS credit and errors in computing interest and fees were treated as computational matters requiring verification and were remitted to the Assessing Officer for fresh consideration after providing an opportunity of hearing. The appeal was consequently partly allowed.
Under the combined transaction approach to TNMM, separate benchmarking of royalty and Global Accounts Manager charges is impermissible where those costs are already included in the operating costs of the logistics segment being benchmarked. The transfer pricing adjustments for those items were therefore deleted, consistent with the principle that individual cost elements embedded in an accepted combined segment analysis should not be separately benchmarked without a corresponding cost-base adjustment. Claims concerning TDS credit and errors in computing interest and fees were treated as computational matters requiring verification and were remitted to the Assessing Officer for fresh consideration after providing an opportunity of hearing. The appeal was consequently partly allowed.
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