Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
In a transfer pricing dispute over specified domestic transactions for purchase of potatoes from an associated enterprise, the Tribunal held that the earlier coordinate bench ruling in the assessee's own case for the preceding year governed the issue on identical facts. Applying judicial discipline, it rejected the DRP's attempt to keep the matter open for the Revenue and found that CUP was not the most appropriate method. TNMM was upheld as the appropriate arm's length method, so the transfer pricing adjustment based on CUP was deleted. As the substantive addition did not survive, the consequential penalty proceedings for alleged under-reporting or misreporting under section 270A were rendered infructuous.
In a transfer pricing dispute over specified domestic transactions for purchase of potatoes from an associated enterprise, the Tribunal held that the earlier coordinate bench ruling in the assessee's own case for the preceding year governed the issue on identical facts. Applying judicial discipline, it rejected the DRP's attempt to keep the matter open for the Revenue and found that CUP was not the most appropriate method. TNMM was upheld as the appropriate arm's length method, so the transfer pricing adjustment based on CUP was deleted. As the substantive addition did not survive, the consequential penalty proceedings for alleged under-reporting or misreporting under section 270A were rendered infructuous.
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