International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Directives address transfer pricing comparables and an ECB interest adjustment: three comparables newly available are to be included in the TP study and one additional comparable (previously directed) must be included; one comparable is to be excluded as functionally dissimilar because it serves specialized defence R&D activities unlike the taxpayer's telecom operations; an interest addition on unsecured related-party external commercial borrowing is deleted by application of the consistency principle since identical borrowings and interest were accepted in earlier years. Outcomes: include specified comparables, exclude the functionally dissimilar comparable, and delete the ECB interest adjustment.
Directives address transfer pricing comparables and an ECB interest adjustment: three comparables newly available are to be included in the TP study and one additional comparable (previously directed) must be included; one comparable is to be excluded as functionally dissimilar because it serves specialized defence R&D activities unlike the taxpayer's telecom operations; an interest addition on unsecured related-party external commercial borrowing is deleted by application of the consistency principle since identical borrowings and interest were accepted in earlier years. Outcomes: include specified comparables, exclude the functionally dissimilar comparable, and delete the ECB interest adjustment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
