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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Release of buyback escrow under the exceptions to Regulation 15B(8) does not bar an independent fraud inquiry under the PFUTP Regulations, because the provision concerns escrow forfeiture or release rather than whether fraud occurred. Internal departmental file notings remain non-binding unless converted into and communicated as a final decision of the competent authority. Fraud must be proved on a balance of probabilities through objective, corroborative circumstances, including trading patterns, contemporaneous records and attributable conduct. The fraud allegation was remanded for fresh adjudication after examination of trading-data discrepancies, inconsistent investigation reports and corroborative material; the appeals were partly allowed.
Release of buyback escrow under the exceptions to Regulation 15B(8) does not bar an independent fraud inquiry under the PFUTP Regulations, because the provision concerns escrow forfeiture or release rather than whether fraud occurred. Internal departmental file notings remain non-binding unless converted into and communicated as a final decision of the competent authority. Fraud must be proved on a balance of probabilities through objective, corroborative circumstances, including trading patterns, contemporaneous records and attributable conduct. The fraud allegation was remanded for fresh adjudication after examination of trading-data discrepancies, inconsistent investigation reports and corroborative material; the appeals were partly allowed.
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