Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through agreement, correspondence, invoices, payments, and improved revenue and profitability. The Dispute Resolution Panel arbitrarily upheld the Transfer Pricing Officer's determination of nil value without examining facts and legal precedents. The Tribunal set aside the adjustment, reinstating the assessee's transfer pricing analysis using the Transactional Net Margin Method. Regarding imputed interest on delayed receivables, the Tribunal followed precedents that working capital adjustment subsumes interest on receivables, eliminating separate benchmarking. As the assessee's profit level indicators after working capital adjustment were better than comparables, imputing notional interest was unwarranted. The interest adjustment was deleted in favor of the assessee.
Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through agreement, correspondence, invoices, payments, and improved revenue and profitability. The Dispute Resolution Panel arbitrarily upheld the Transfer Pricing Officer's determination of nil value without examining facts and legal precedents. The Tribunal set aside the adjustment, reinstating the assessee's transfer pricing analysis using the Transactional Net Margin Method. Regarding imputed interest on delayed receivables, the Tribunal followed precedents that working capital adjustment subsumes interest on receivables, eliminating separate benchmarking. As the assessee's profit level indicators after working capital adjustment were better than comparables, imputing notional interest was unwarranted. The interest adjustment was deleted in favor of the assessee.
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