Condonation of Delay denied: communication lapses and corporate restructuring found insufficient; prolonged inaction and lack of bona fides led to ref...
Export Support intervention INSIGHT launched to provide non financial capacity building, trade intelligence and pilot support with defined funding and...
Transfer pricing adjustment arising from royalty payments requires benchmarking by the most appropriate traditional transaction method; where exact identical comparables exist the CUP method should be applied, but selected comparables must be functionally comparable and not mere local manufacturers or brand developers. The impugned comparables were held inappropriate and the matter is remitted to AO/TPO to re-benchmark afresh after affording the assessee hearing and considering the submitted TPAR; if no exact comparables receiving bundled services are found, benchmarking should proceed under TNMM using proper comparables.
Transfer pricing adjustment arising from royalty payments requires benchmarking by the most appropriate traditional transaction method; where exact identical comparables exist the CUP method should be applied, but selected comparables must be functionally comparable and not mere local manufacturers or brand developers. The impugned comparables were held inappropriate and the matter is remitted to AO/TPO to re-benchmark afresh after affording the assessee hearing and considering the submitted TPAR; if no exact comparables receiving bundled services are found, benchmarking should proceed under TNMM using proper comparables.
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