Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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TP adjustment - Comparable selection - if finances of the three comparables with reference to their respective annual reports, did show that there was a general trend in the industry of either loss-making or declining revenues and there was no dispute on the functional profile of the Assessee being similar with comparable then loss making companies should not be excluded only on that basis
TP adjustment - Comparable selection - if finances of the three comparables with reference to their respective annual reports, did show that there was a general trend in the industry of either loss-making or declining revenues and there was no dispute on the functional profile of the Assessee being similar with comparable then loss making companies should not be excluded only on that basis
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