Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
Internal CUP was treated as the most appropriate method for determining the arm's length price of project-office transactions under a turnkey power-project contract. Where the Indian project office bore the contract's risks and rewards, all revenue was attributed to India, and the unrelated customer regarded the head office and project office as one entity, the contract with that customer satisfied the comparability requirements for an internal CUP. CUP was preferred over TNMM as a more direct and suitable method, while the proposed TNMM comparables were rejected. The transfer-pricing adjustment was consequently not sustained, and the appeals were dismissed for lack of a substantial question of law.
Internal CUP was treated as the most appropriate method for determining the arm's length price of project-office transactions under a turnkey power-project contract. Where the Indian project office bore the contract's risks and rewards, all revenue was attributed to India, and the unrelated customer regarded the head office and project office as one entity, the contract with that customer satisfied the comparability requirements for an internal CUP. CUP was preferred over TNMM as a more direct and suitable method, while the proposed TNMM comparables were rejected. The transfer-pricing adjustment was consequently not sustained, and the appeals were dismissed for lack of a substantial question of law.
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