Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
Turnover is a relevant comparability factor in transfer pricing because scale affects profitability, risk and economies of scale; disproportionately large software companies were therefore excluded, while judicial discipline and the doctrine of merger required following the jurisdictional High Court view. Companies lacking reliable segmental data, showing mixed product and service activities, or failing employee cost and service revenue filters were treated as unsuitable comparables. By the same functional test, a software services company with support from its annual report was included. In the marketing support segment, an indenting and trading entity was excluded, while an advertising agency was included because advertising and marketing support operate in the same promotional domain.
Turnover is a relevant comparability factor in transfer pricing because scale affects profitability, risk and economies of scale; disproportionately large software companies were therefore excluded, while judicial discipline and the doctrine of merger required following the jurisdictional High Court view. Companies lacking reliable segmental data, showing mixed product and service activities, or failing employee cost and service revenue filters were treated as unsuitable comparables. By the same functional test, a software services company with support from its annual report was included. In the marketing support segment, an indenting and trading entity was excluded, while an advertising agency was included because advertising and marketing support operate in the same promotional domain.
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