Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
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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.
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