Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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