Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
Diagnostic microcuvette classification follows sole-use analytical function, placing specialised disposable cuvettes with their analyser rather than g...
Customs Broker licensing proceedings fail when their offence-report foundation collapses and authorisation, advisory, and KYC duties remain unbreached...
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Separate transfer-pricing adjustment for notional interest on delayed trade receivables from associated enterprises is not warranted where the taxpayer is completely debt-free and bears no interest cost on borrowings, because delayed collection creates no additional financing burden. Debt-free status requires verification from financial statements and other relevant records. If verified, the adjustment for interest on outstanding receivables is deleted. This approach applies across the assessment years concerned.
Separate transfer-pricing adjustment for notional interest on delayed trade receivables from associated enterprises is not warranted where the taxpayer is completely debt-free and bears no interest cost on borrowings, because delayed collection creates no additional financing burden. Debt-free status requires verification from financial statements and other relevant records. If verified, the adjustment for interest on outstanding receivables is deleted. This approach applies across the assessment years concerned.
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