Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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Transfer-pricing adjustment on raw-material purchases routed through a pass-through associated enterprise is not warranted where the unrelated foreign supplier directly supplies the goods and credit notes reduce the effective price to that supplier's price. An additional invoiced component used solely for customs-duty valuation does not justify an arm's length price adjustment in those circumstances. Compliance with the direction concerning operating revenue results in no further adjustment. The transfer-pricing adjustment on these purchases was deleted and the appeal allowed.
Transfer-pricing adjustment on raw-material purchases routed through a pass-through associated enterprise is not warranted where the unrelated foreign supplier directly supplies the goods and credit notes reduce the effective price to that supplier's price. An additional invoiced component used solely for customs-duty valuation does not justify an arm's length price adjustment in those circumstances. Compliance with the direction concerning operating revenue results in no further adjustment. The transfer-pricing adjustment on these purchases was deleted and the appeal allowed.
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