Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The ruling determines that bundled sale of printing inks and various consumables is not a composite supply because the bundle is not 'naturally bundled' nor does any single good qualify as the 'principal supply'; instead the package is a mixed supply and taxable accordingly. The supply is a continuous supply with periodic invoicing; time of supply is the earlier of invoice date or payment under Section 12(2). Transaction value is the per-click/per-impression amount stated in the invoice and governs valuation under Section 15.
The ruling determines that bundled sale of printing inks and various consumables is not a composite supply because the bundle is not 'naturally bundled' nor does any single good qualify as the 'principal supply'; instead the package is a mixed supply and taxable accordingly. The supply is a continuous supply with periodic invoicing; time of supply is the earlier of invoice date or payment under Section 12(2). Transaction value is the per-click/per-impression amount stated in the invoice and governs valuation under Section 15.
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