Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
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.
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