Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
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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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