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Tariff rate quota authorisations govern preferential imports of specified New Zealand goods through export certification and electronic customs debiti...
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TP Adjustment - Comparable selection - determination of the arm’s length price (ALP) of international transactions - The appellant contested the inclusion of two companies, Roto Pumps Ltd. and Simmonds Marshall Ltd., as comparables due to product dissimilarity. The Appellate Tribunal upheld the exclusion of these comparables, emphasizing their dissimilar businesses compared to the appellant. Additionally, the Tribunal dismissed the appellant's objections regarding capacity utilization adjustment, PLI calculation, and treatment of foreign exchange gain/loss, as they became inconsequential post the exclusion of the disputed comparables.
TP Adjustment - Comparable selection - determination of the arm’s length price (ALP) of international transactions - The appellant contested the inclusion of two companies, Roto Pumps Ltd. and Simmonds Marshall Ltd., as comparables due to product dissimilarity. The Appellate Tribunal upheld the exclusion of these comparables, emphasizing their dissimilar businesses compared to the appellant. Additionally, the Tribunal dismissed the appellant's objections regarding capacity utilization adjustment, PLI calculation, and treatment of foreign exchange gain/loss, as they became inconsequential post the exclusion of the disputed comparables.
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TaxTMI 
TaxTMI 
of 4921 
