Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
TP adjustment - Inclusion of excise duty on the operating revenue for two comparables - By including excise duty in the case of two comparables by the ld. TPO, the operating profit has been artificially increased by the amount of excise duty and, therefore, the PLI computed by the learned TPO stands comparatively incorrect. We thus, find no fault with the computation of PLI after netting of excise duty done by the assessee for the purpose of benchmarking its sale and purchase transactions of raw material and goods with its AEs. - AT
TP adjustment - Inclusion of excise duty on the operating revenue for two comparables - By including excise duty in the case of two comparables by the ld. TPO, the operating profit has been artificially increased by the amount of excise duty and, therefore, the PLI computed by the learned TPO stands comparatively incorrect. We thus, find no fault with the computation of PLI after netting of excise duty done by the assessee for the purpose of benchmarking its sale and purchase transactions of raw material and goods with its AEs. - AT
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