Opportunity to respond to jurisdictional reports is mandatory before customs settlement duty enhancement; connected applications require consistent ad...
Specific customs headings for scaffolding components prevail over general classification, invalidating misclassification proceedings and enabling with...
Liquidator appointment under Section 34 requires consideration of creditor recommendations, valid professional authorisation, and preservation of vali...
TNMM comparability for marketing-support commission should primarily rest on functional, asset and risk analysis where reliable segmental data exists. A low-risk indenting-services segment without inventory or credit risk may be comparable despite the entity's wider trading activity or different products. LIBOR is the appropriate benchmark for foreign-currency loans to wholly owned subsidiaries; additional risk mark-up requires demonstrated differential risk, and contractual LIBOR-plus rates may be arm's length. Delayed associated-enterprise receivables remain separately examinable international transactions, but notional interest should not be charged where working-capital adjustment already captures the receivables effect and the tested party's adjusted margin exceeds comparable margins, subject to verification.
TNMM comparability for marketing-support commission should primarily rest on functional, asset and risk analysis where reliable segmental data exists. A low-risk indenting-services segment without inventory or credit risk may be comparable despite the entity's wider trading activity or different products. LIBOR is the appropriate benchmark for foreign-currency loans to wholly owned subsidiaries; additional risk mark-up requires demonstrated differential risk, and contractual LIBOR-plus rates may be arm's length. Delayed associated-enterprise receivables remain separately examinable international transactions, but notional interest should not be charged where working-capital adjustment already captures the receivables effect and the tested party's adjusted margin exceeds comparable margins, subject to verification.
Note: It is a system-generated summary and is for quick reference only.
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