Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Pre-existing disputes over outcome-based professional fees can bar Section 9 insolvency proceedings where contractual entitlement requires investigati...
Corresponding scheduled offences preserve money-laundering jurisdiction despite repeal of the central corruption provision where conduct remains cover...
Export incentives directly connected with export activity are treated as operating income when computing the tested party's profit level indicator under the Transactional Net Margin Method. Excluding such incentives can distort the tested party's operating margin, particularly where incentives received by comparable companies are included in their operating income. The operating and arm's-length margins should therefore be recomputed after including eligible export incentives in the tested party's operating results.
Export incentives directly connected with export activity are treated as operating income when computing the tested party's profit level indicator under the Transactional Net Margin Method. Excluding such incentives can distort the tested party's operating margin, particularly where incentives received by comparable companies are included in their operating income. The operating and arm's-length margins should therefore be recomputed after including eligible export incentives in the tested party's operating results.
Note: It is a system-generated summary and is for quick reference only.