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...
Liability for non-registration turned on allocation of operational roles under the MOU and Guidelines: uploading contracts to the foreign online portal was the foreign authority's distinct obligation, while the domestic authority's duty arose only to verify entries already reflected on that portal; consequently the domestic authority could not be held liable for the foreign authority's failure to upload. Challenges to fixation of the Country Cap and its allocation raised economic policy issues; the court declined to substitute judgment for a plausible policy decision absent manifest arbitrariness, unreasonableness, or mala fides, and found no violation of equality or trade rights.
Liability for non-registration turned on allocation of operational roles under the MOU and Guidelines: uploading contracts to the foreign online portal was the foreign authority's distinct obligation, while the domestic authority's duty arose only to verify entries already reflected on that portal; consequently the domestic authority could not be held liable for the foreign authority's failure to upload. Challenges to fixation of the Country Cap and its allocation raised economic policy issues; the court declined to substitute judgment for a plausible policy decision absent manifest arbitrariness, unreasonableness, or mala fides, and found no violation of equality or trade rights.
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