Mandatory verification procedure governs rejection of country-of-origin certificates before denying preferential customs exemption and related penalti...
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TP Adjustment - comparable selection - upper turnover filter - The assessee submits that the turnover of the assessee is only Rs. 124 Crores during the relevant previous year, hence, companies having turnover of more than Rs. 200 Crores needs to be excluded from the comparable list while calculating the ALP of the said international transaction. Following the earlier decision in assessee’s own case the Tribunal restored the matter before the AO with a direction to adopt upper turnover filter of Rs. 200 Crores.
TP Adjustment - comparable selection - upper turnover filter - The assessee submits that the turnover of the assessee is only Rs. 124 Crores during the relevant previous year, hence, companies having turnover of more than Rs. 200 Crores needs to be excluded from the comparable list while calculating the ALP of the said international transaction. Following the earlier decision in assessee’s own case the Tribunal restored the matter before the AO with a direction to adopt upper turnover filter of Rs. 200 Crores.
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