Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Export incentives directly connected with export activity are treated as operating income when computing the tested party's profit level indicator under the Transactional Net Margin Method. Excluding such incentives can distort the tested party's operating margin, particularly where incentives received by comparable companies are included in their operating income. The operating and arm's-length margins should therefore be recomputed after including eligible export incentives in the tested party's operating results.
Export incentives directly connected with export activity are treated as operating income when computing the tested party's profit level indicator under the Transactional Net Margin Method. Excluding such incentives can distort the tested party's operating margin, particularly where incentives received by comparable companies are included in their operating income. The operating and arm's-length margins should therefore be recomputed after including eligible export incentives in the tested party's operating results.
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