Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
Integrated international transactions forming a single chain of product design, validation, manufacturing and sale were held to be benchmarkable under aggregated TNMM, and selective segregation of management, testing and validation services was rejected because the assessee's operating margin exceeded the comparable mean. The Transfer Pricing Officer could not fix arm's length price at nil without applying a recognised method, especially where records showed actual rendition of services. Outstanding receivables were treated as closely linked to the principal transaction and not separately benchmarked; with working capital adjustment already allowed and the assessee being debt-free, no notional interest adjustment survived. The appeal was allowed and the transfer pricing additions were deleted.
Integrated international transactions forming a single chain of product design, validation, manufacturing and sale were held to be benchmarkable under aggregated TNMM, and selective segregation of management, testing and validation services was rejected because the assessee's operating margin exceeded the comparable mean. The Transfer Pricing Officer could not fix arm's length price at nil without applying a recognised method, especially where records showed actual rendition of services. Outstanding receivables were treated as closely linked to the principal transaction and not separately benchmarked; with working capital adjustment already allowed and the assessee being debt-free, no notional interest adjustment survived. The appeal was allowed and the transfer pricing additions were deleted.
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