Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
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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