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 ...
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Cost Plus Method based on an internal comparable was treated as the most appropriate method for software development services where identical services were supplied to an independent entity at the same cost-plus mark-up. A traditional pricing method cannot be replaced by a transactional profit method without cogent reasons demonstrating its inadequacy, including proper consideration of the functions, assets and risks analysis. The services were at arm's length and the transfer-pricing adjustment was deleted. No interest adjustment arose on delayed associated-enterprise receivables because interest was not charged on comparable delayed payments by unrelated parties; that adjustment was also deleted.
Cost Plus Method based on an internal comparable was treated as the most appropriate method for software development services where identical services were supplied to an independent entity at the same cost-plus mark-up. A traditional pricing method cannot be replaced by a transactional profit method without cogent reasons demonstrating its inadequacy, including proper consideration of the functions, assets and risks analysis. The services were at arm's length and the transfer-pricing adjustment was deleted. No interest adjustment arose on delayed associated-enterprise receivables because interest was not charged on comparable delayed payments by unrelated parties; that adjustment was also deleted.
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