Employee conflict disclosures and investment restrictions expand with new recusal duties, post-employment limits, and compliance reporting requirement...
Revenue-neutral domestic transfer pricing and mirror transactions justified deletion of related-party adjustments for operation, maintenance and port ...
TP adjustment - The TPO has not given any reason as to why he altered the aggregate amount of Net profit. Hence the workings made by TPO is liable to rejected. We have noticed that the net profit margin worked out by the assessee in "Domestic - Personal care division" was 12.31%. The net profit margin worked out for "Exports to AEs" was 24.03%. Hence the net profit margin earned in the exports to AEs division is higher than its comparable "Domestic - Personal care division". Hence it has to be held that the international transactions of making exports to AEs are at arms length and hence no T.P adjustment is called for. - AT
TP adjustment - The TPO has not given any reason as to why he altered the aggregate amount of Net profit. Hence the workings made by TPO is liable to rejected. We have noticed that the net profit margin worked out by the assessee in "Domestic - Personal care division" was 12.31%. The net profit margin worked out for "Exports to AEs" was 24.03%. Hence the net profit margin earned in the exports to AEs division is higher than its comparable "Domestic - Personal care division". Hence it has to be held that the international transactions of making exports to AEs are at arms length and hence no T.P adjustment is called for. - AT
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