Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
Transfer pricing dispute over benchmarking of AMP expenses and appropriate ALP method: the Bright Line Test (BLT) adjustments are held legally unsustainable and deleted; the Cost Plus method is rejected as unjustified because the assessee acted as a distributor incurring routine business promotion and employee costs that should form part of trading cost; the tribunal accepts comparability under adjusted TNMM and directs an ALP uplift equal to the difference between the comparable PLI and the assessee's margin, instructing the AO to compute and apply that limited adjustment in line with the cited Sony Ericsson precedent.
Transfer pricing dispute over benchmarking of AMP expenses and appropriate ALP method: the Bright Line Test (BLT) adjustments are held legally unsustainable and deleted; the Cost Plus method is rejected as unjustified because the assessee acted as a distributor incurring routine business promotion and employee costs that should form part of trading cost; the tribunal accepts comparability under adjusted TNMM and directs an ALP uplift equal to the difference between the comparable PLI and the assessee's margin, instructing the AO to compute and apply that limited adjustment in line with the cited Sony Ericsson precedent.
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