Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Process amounting to manufacture - The appellant's contention was that the activities—testing, labeling, and packing—performed on imported modems did not amount to manufacture, as the modems were already in a marketable state upon import. They argued that these processes were essential quality checks and did not alter the modem's identity, thus not constituting manufacture. - The Tribunal held that testing, labeling, and packing of modems, coupled with the inclusion of additional accessories, amounted to making the product marketable to the consumer, thereby falling within the definition of manufacture.
Process amounting to manufacture - The appellant's contention was that the activities—testing, labeling, and packing—performed on imported modems did not amount to manufacture, as the modems were already in a marketable state upon import. They argued that these processes were essential quality checks and did not alter the modem's identity, thus not constituting manufacture. - The Tribunal held that testing, labeling, and packing of modems, coupled with the inclusion of additional accessories, amounted to making the product marketable to the consumer, thereby falling within the definition of manufacture.
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