Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
TP Adjustment - 'arranged' pricing' - TNMM method or CUP method - the superiority of any particular method to arrive at the ALP is ruled out.The TNMM (Transactional Net Margin Method) requires establishing comparability level at a broad functional level. It requires comparison between net margin derived from operation of the uncontrolled parties and net margin derived by an associated enterprise on similar operation. The net profit margin earned by an associate enterprise is compared with net profit margin of uncontrolled transactions to arrive at arm's length price. - Thus CUP method was found to be more appropriate - HC
TP Adjustment - 'arranged' pricing' - TNMM method or CUP method - the superiority of any particular method to arrive at the ALP is ruled out.The TNMM (Transactional Net Margin Method) requires establishing comparability level at a broad functional level. It requires comparison between net margin derived from operation of the uncontrolled parties and net margin derived by an associated enterprise on similar operation. The net profit margin earned by an associate enterprise is compared with net profit margin of uncontrolled transactions to arrive at arm's length price. - Thus CUP method was found to be more appropriate - HC
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