Risk-based postal import clearance standardises electronic assessment, document requests, duty realisation and delivery controls at Foreign Post Offic...
Customs Cargo Service Provider appointment extends custodianship to additional terminal land, subject to cargo-control, security and licence condition...
Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
The case involves Transfer Pricing (TP) adjustments and the classification of segments for benchmarking purposes. The Appellate Tribunal held that TP adjustments should be based on transactions with Associated Enterprises (AEs) only. The Tribunal directed the Assessing Officer/TPO to consider only the operating profit/cost of AE segments and to apply the Transactional Net Margin Method (TNMM) for services rendered to AEs. The issue of using Resale Price Method (RPM) for the trading segment was also referred back to verify if value addition was made. The classification of the assessee as a manufacturing segment was questioned, and the Tribunal directed verification based on transaction volumes. The Tribunal agreed with the DRP that TP adjustments should be limited to AE transactions only when TNMM is adopted as the Most Appropriate Method (MAM). The appeal was allowed for statistical purposes.
The case involves Transfer Pricing (TP) adjustments and the classification of segments for benchmarking purposes. The Appellate Tribunal held that TP adjustments should be based on transactions with Associated Enterprises (AEs) only. The Tribunal directed the Assessing Officer/TPO to consider only the operating profit/cost of AE segments and to apply the Transactional Net Margin Method (TNMM) for services rendered to AEs. The issue of using Resale Price Method (RPM) for the trading segment was also referred back to verify if value addition was made. The classification of the assessee as a manufacturing segment was questioned, and the Tribunal directed verification based on transaction volumes. The Tribunal agreed with the DRP that TP adjustments should be limited to AE transactions only when TNMM is adopted as the Most Appropriate Method (MAM). The appeal was allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
Join Channel
TaxTMI 
