Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Under TNMM, a Basmati rice trader that only procures and exports...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export receipts.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Under TNMM, a Basmati rice trader that only procures and exports rice to its associated enterprise should be benchmarked against entities with comparable trading functions, assets and risks. Diversified commodity trading and rice milling, processing or manufacturing companies were treated as functionally dissimilar and excluded; milling and processing, rather than non-Basmati dealings or profitability alone, determined exclusion. Segmental trading results of a diversified company required reconsideration where trading represented its predominant revenue. Cash discounts reducing rice purchase cost and export incentives from licence sales were treated as operating income, since their exclusion would distort the operating-profit comparison. The transfer-pricing adjustment required recomputation on these bases.
Under TNMM, a Basmati rice trader that only procures and exports rice to its associated enterprise should be benchmarked against entities with comparable trading functions, assets and risks. Diversified commodity trading and rice milling, processing or manufacturing companies were treated as functionally dissimilar and excluded; milling and processing, rather than non-Basmati dealings or profitability alone, determined exclusion. Segmental trading results of a diversified company required reconsideration where trading represented its predominant revenue. Cash discounts reducing rice purchase cost and export incentives from licence sales were treated as operating income, since their exclusion would distort the operating-profit comparison. The transfer-pricing adjustment required recomputation on these bases.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
