Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
TP Adjustment - selection of most appropriate method (MAM) - Resale Price Method or Transactional Net Margin Method - Introduction of Fresh Comparables - Removal of 3% Filter - The Tribunal upholds the adoption of Transactional Net Margin Method (TNMM) over Resale Price Method (RPM), citing subsequent TNMM usage and functional comparability. It supports the introduction of new comparables and the rejection of the 3% filter due to marketing intensity. The Tribunal confirms the deletion of additions based on selected comparables' margin comparison with the appellant.
TP Adjustment - selection of most appropriate method (MAM) - Resale Price Method or Transactional Net Margin Method - Introduction of Fresh Comparables - Removal of 3% Filter - The Tribunal upholds the adoption of Transactional Net Margin Method (TNMM) over Resale Price Method (RPM), citing subsequent TNMM usage and functional comparability. It supports the introduction of new comparables and the rejection of the 3% filter due to marketing intensity. The Tribunal confirms the deletion of additions based on selected comparables' margin comparison with the appellant.
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