FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Upper turnover filters in transfer-pricing comparable selection may be applied where differences in turnover, brand value, economies of scale, bargaining power and ownership of intangibles materially affect profitability and comparability. High-turnover software-development companies were treated as unsuitable comparables because their scale and functional profile differed from that of the tested party. The approach supports excluding enterprises exceeding the stated turnover threshold when scale-related factors distort an arm's-length comparison.
Upper turnover filters in transfer-pricing comparable selection may be applied where differences in turnover, brand value, economies of scale, bargaining power and ownership of intangibles materially affect profitability and comparability. High-turnover software-development companies were treated as unsuitable comparables because their scale and functional profile differed from that of the tested party. The approach supports excluding enterprises exceeding the stated turnover threshold when scale-related factors distort an arm's-length comparison.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
