TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
Co-terminus appellate powers require full verification before deleting TDS disallowances for alleged non-deduction of tax on freight-forwarding paymen...
Imported educational software supplied on CDs to educational institutions was treated as packaged, rather than customized, software where identical unmodifiable products were marketed to varied users and related consultation, installation, training and support did not alter the software. MRP/RSP-based valuation applied because packages lacked the mandatory "not for retail sale" declaration required for the industrial or institutional consumer exclusion. Customer and sub-reseller invoices supported the retail sale price; installation, training and support costs were not deductible without a separate invoice break-up. Non-declaration of MRP supported extended limitation, confiscation and penalties, sustained alongside differential CVD.
Imported educational software supplied on CDs to educational institutions was treated as packaged, rather than customized, software where identical unmodifiable products were marketed to varied users and related consultation, installation, training and support did not alter the software. MRP/RSP-based valuation applied because packages lacked the mandatory "not for retail sale" declaration required for the industrial or institutional consumer exclusion. Customer and sub-reseller invoices supported the retail sale price; installation, training and support costs were not deductible without a separate invoice break-up. Non-declaration of MRP supported extended limitation, confiscation and penalties, sustained alongside differential CVD.
Note: It is a system-generated summary and is for quick reference only.