Personal hearing requirements in GST adjudication were satisfied by prior opportunities and written submissions; appellate limitation received writ-pe...
Interactive flat panels meeting automatic data processing conditions are distinguished from monitors, while later classification clarifications apply ...
Page of 4813
Press 'Enter' after typing page number.
1061 to 1080 of 96257 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Transfer pricing analysis under External TNMM remained the proper benchmarking method where the earlier remand had already excluded Internal TNMM and limited scrutiny to the comparables selected by the assessee. The text explains that mechanical turnover, export and product-difference filters could not justify wiping out the external comparable set for a limited-risk contract manufacturer earning a cost-plus return, and that comparable selection must reflect functions, assets and risks. It further states that AE and Non-AE segments were not internally comparable because the Non-AE business was entrepreneurial and risk-bearing, while audited segmental accounts could not be reworked absent specific defects. On that basis, the segmental results were restored and the transfer pricing adjustments were deleted.
Transfer pricing analysis under External TNMM remained the proper benchmarking method where the earlier remand had already excluded Internal TNMM and limited scrutiny to the comparables selected by the assessee. The text explains that mechanical turnover, export and product-difference filters could not justify wiping out the external comparable set for a limited-risk contract manufacturer earning a cost-plus return, and that comparable selection must reflect functions, assets and risks. It further states that AE and Non-AE segments were not internally comparable because the Non-AE business was entrepreneurial and risk-bearing, while audited segmental accounts could not be reworked absent specific defects. On that basis, the segmental results were restored and the transfer pricing adjustments were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4813 
Join Channel 
