Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Cross-segment derivatives manipulation: integrated order patterns can support interim restraints, while director liability requires responsibility, co...
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 4907 
