Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
SEIS-related income had been consistently treated as non-operating, so its reversal was also required to be treated similarly to preserve comparability in TNMM margin analysis. Foreign exchange fluctuation arising from realisation of export receivables was held to be intrinsically linked to publishing support services and therefore operating in nature. On that basis, the assessee's margin fell within the arm's length range and the transfer pricing adjustment on publishing support services was deleted. The Tribunal also held that working capital adjustment is a recognised comparability adjustment under TNMM and cannot be denied merely because daily data is unavailable; reasonable approximations from opening and closing balances may be used. The AO/TPO was directed to grant the adjustment, and no further TP adjustment survived on this issue.
SEIS-related income had been consistently treated as non-operating, so its reversal was also required to be treated similarly to preserve comparability in TNMM margin analysis. Foreign exchange fluctuation arising from realisation of export receivables was held to be intrinsically linked to publishing support services and therefore operating in nature. On that basis, the assessee's margin fell within the arm's length range and the transfer pricing adjustment on publishing support services was deleted. The Tribunal also held that working capital adjustment is a recognised comparability adjustment under TNMM and cannot be denied merely because daily data is unavailable; reasonable approximations from opening and closing balances may be used. The AO/TPO was directed to grant the adjustment, and no further TP adjustment survived on this issue.
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