Interactive flat panels meeting automatic data processing conditions are distinguished from monitors, while later classification clarifications apply ...
Statutory transfer formalities invalidated alleged share and property transfers, while retrospective record manipulation constituted oppression and mi...
Provisional attachment of laundered funds and equivalent-value property sustained, with statutory protection limited to pension, gratuity and providen...
Transfer-pricing method selection between the Comparable Uncontrolled Price method and the Transactional Net Margin Method is primarily a fact-based benchmarking issue. The Tribunal's acceptance of TNMM as the most appropriate method was treated as sustainable where it was not perverse or contrary to the record. Mere disagreement over the appropriate method does not create a substantial question of law under section 260A unless the selected method contravenes prescribed rules. Differences between associated-enterprise and non-associated-enterprise transactions were also considered within the benchmarking analysis. The tax appeals were dismissed because the transfer-pricing questions raised no substantial question of law.
Transfer-pricing method selection between the Comparable Uncontrolled Price method and the Transactional Net Margin Method is primarily a fact-based benchmarking issue. The Tribunal's acceptance of TNMM as the most appropriate method was treated as sustainable where it was not perverse or contrary to the record. Mere disagreement over the appropriate method does not create a substantial question of law under section 260A unless the selected method contravenes prescribed rules. Differences between associated-enterprise and non-associated-enterprise transactions were also considered within the benchmarking analysis. The tax appeals were dismissed because the transfer-pricing questions raised no substantial question of law.
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