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...
Transfer-pricing comparability under TNMM requires a FAR analysis; company size may support a turnover filter, excluding high-turnover entities when determining arm's length remuneration for software development services. Where depreciation materially differs because of asset types, technology or investment levels, a cash profit level indicator excluding depreciation may compare real margins. Provision for bad and doubtful debts remains operating expenditure unless extraordinary. Free-use testing equipment supplied by an associated enterprise does not create a taxable business perquisite where ownership remains with the enterprise, no depreciation is claimed, and use is confined to testing software for it.
Transfer-pricing comparability under TNMM requires a FAR analysis; company size may support a turnover filter, excluding high-turnover entities when determining arm's length remuneration for software development services. Where depreciation materially differs because of asset types, technology or investment levels, a cash profit level indicator excluding depreciation may compare real margins. Provision for bad and doubtful debts remains operating expenditure unless extraordinary. Free-use testing equipment supplied by an associated enterprise does not create a taxable business perquisite where ownership remains with the enterprise, no depreciation is claimed, and use is confined to testing software for it.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
