Actual-user customs exemption conditions permit turnkey project transfers when imported windmill components are exclusively used for installation and ...
Customs offence disqualification excludes civil contraventions, preventing refusal of a private bonded warehouse licence based solely on monetary pena...
Residual food-preparation classification places fermented Nata De Coco outside fruit-jelly categories, changing its GST treatment across notified peri...
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The High Court upheld the decision of the ITAT regarding the selection of comparables for benchmarking analysis under the Transactional Net Margin Method (TNMM). The court concurred that companies like Kitco Ltd., TCE Consulting Engineers Ltd., Project and Development India Ltd., and Mahindra Consulting Engineers Ltd. were not appropriate comparables for the assessee, who was engaged in engineering and design services. Despite the TNMM's tolerance for functional dissimilarities, the comparables' broad functional profiles must be similar. Comparing entities with different functionalities solely based on the TNMM's tolerance would be erroneous. The ITAT's findings aligned with the arm's length principle provisions u/s 92C of the Income Tax Act.
The High Court upheld the decision of the ITAT regarding the selection of comparables for benchmarking analysis under the Transactional Net Margin Method (TNMM). The court concurred that companies like Kitco Ltd., TCE Consulting Engineers Ltd., Project and Development India Ltd., and Mahindra Consulting Engineers Ltd. were not appropriate comparables for the assessee, who was engaged in engineering and design services. Despite the TNMM's tolerance for functional dissimilarities, the comparables' broad functional profiles must be similar. Comparing entities with different functionalities solely based on the TNMM's tolerance would be erroneous. The ITAT's findings aligned with the arm's length principle provisions u/s 92C of the Income Tax Act.
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