Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
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Transfer-pricing adjustment for intra-group management, sales and support services was deleted after the Tribunal applied a co-ordinate Bench decision to the material facts. The adjustment had determined the arm's length price of those services at nil. The appeal was allowed on this issue, while the remaining grounds were left open.
Transfer-pricing adjustment for intra-group management, sales and support services was deleted after the Tribunal applied a co-ordinate Bench decision to the material facts. The adjustment had determined the arm's length price of those services at nil. The appeal was allowed on this issue, while the remaining grounds were left open.
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