Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Objective characteristics govern magnesium bis-glycinate chelate classification as an amino-acid coordination compound, not a food preparation or anti...
Independent professional certification requires pleaded knowledge or complicity for criminal liability; untimely complaints remain barred by limitatio...
A modified return filed by a successor following an NCLT-approved business reorganisation must be examined within the scope of the reorganisation order for recomputation of income. Under MAT, transfer pricing adjustments under normal provisions cannot increase book profit unless authorised by a specified adjustment to certified accounts. For transfer pricing, closely linked software sales and support services may be aggregated under TNMM where they form an integrated business model; documented evidence of service rendition and benefit precludes a nil valuation. A foreign associated enterprise may be the tested party if it is the least complex entity, and comparable margins require appropriate period and segmental-data analysis.
A modified return filed by a successor following an NCLT-approved business reorganisation must be examined within the scope of the reorganisation order for recomputation of income. Under MAT, transfer pricing adjustments under normal provisions cannot increase book profit unless authorised by a specified adjustment to certified accounts. For transfer pricing, closely linked software sales and support services may be aggregated under TNMM where they form an integrated business model; documented evidence of service rendition and benefit precludes a nil valuation. A foreign associated enterprise may be the tested party if it is the least complex entity, and comparable margins require appropriate period and segmental-data analysis.
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