Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
For arm's length pricing of preform silica imports, the Comparable Uncontrolled Price (CUP) method applies where reliable internal and external uncontrolled-price data exist for the same raw material. Customs data and internal uncontrolled purchases supported that the associated-enterprise purchase price did not exceed uncontrolled prices. In the absence of changes in the transactions, parties or asset base, a consistently accepted CUP method should not be replaced by the Transactional Net Margin Method (TNMM) without justification. Under TNMM, a diversified manufacturer and service provider without reliable segmental revenue or margin data is not functionally comparable to an entity manufacturing only optical fibre. The CUP-based pricing was accepted, and the TNMM-based transfer-pricing adjustment was deleted.
For arm's length pricing of preform silica imports, the Comparable Uncontrolled Price (CUP) method applies where reliable internal and external uncontrolled-price data exist for the same raw material. Customs data and internal uncontrolled purchases supported that the associated-enterprise purchase price did not exceed uncontrolled prices. In the absence of changes in the transactions, parties or asset base, a consistently accepted CUP method should not be replaced by the Transactional Net Margin Method (TNMM) without justification. Under TNMM, a diversified manufacturer and service provider without reliable segmental revenue or margin data is not functionally comparable to an entity manufacturing only optical fibre. The CUP-based pricing was accepted, and the TNMM-based transfer-pricing adjustment was deleted.
Note: It is a system-generated summary and is for quick reference only.
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