Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Delayed trade receivables from an associated enterprise that remain unpaid beyond the agreed credit period are treated as a separate financing transaction and require independent arm's length benchmarking. Only the delay exceeding the actual arm's length credit period should attract interest, calculated in the receivable currency with a justified spread; LIBOR plus 200 basis points is prescribed for foreign-currency receivables. For ITES comparable selection, verification is required of the service-income and 25% related-party transaction filters. The turnover filter excludes companies with turnover above ten times or below one-tenth of the tested party's turnover.
Delayed trade receivables from an associated enterprise that remain unpaid beyond the agreed credit period are treated as a separate financing transaction and require independent arm's length benchmarking. Only the delay exceeding the actual arm's length credit period should attract interest, calculated in the receivable currency with a justified spread; LIBOR plus 200 basis points is prescribed for foreign-currency receivables. For ITES comparable selection, verification is required of the service-income and 25% related-party transaction filters. The turnover filter excludes companies with turnover above ten times or below one-tenth of the tested party's turnover.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
