Appellate jurisdiction over baggage imports is excluded, requiring confiscation challenges involving passenger-carried gold to proceed by statutory re...
Article 227 review permits intervention in arbitration only for manifest, patent inherent jurisdictional defects, not representational authority dispu...
Transfer-pricing comparability under the transactional net margin method requires economically reliable uncontrolled benchmarks under Section 92C and Rule 10B. Turnover is not a standalone statutory bar, but material scale differences may justify excluding enterprises where brand value, intangibles, bargaining power, assets, risks or market conditions could affect margins. A turnover threshold must therefore be supported by transaction-specific comparability analysis rather than applied as a universal rule. Related-party transaction filters seek to reduce the influence of controlled dealings on comparable profitability. A 15% threshold is ordinarily appropriate where sufficient reliable comparables exist; a higher threshold requires a recorded finding that lower-RPT comparables are unavailable. Functional, asset and risk analysis remains essential, and appellate review may address disregard of statutory criteria or perverse findings.
Transfer-pricing comparability under the transactional net margin method requires economically reliable uncontrolled benchmarks under Section 92C and Rule 10B. Turnover is not a standalone statutory bar, but material scale differences may justify excluding enterprises where brand value, intangibles, bargaining power, assets, risks or market conditions could affect margins. A turnover threshold must therefore be supported by transaction-specific comparability analysis rather than applied as a universal rule. Related-party transaction filters seek to reduce the influence of controlled dealings on comparable profitability. A 15% threshold is ordinarily appropriate where sufficient reliable comparables exist; a higher threshold requires a recorded finding that lower-RPT comparables are unavailable. Functional, asset and risk analysis remains essential, and appellate review may address disregard of statutory criteria or perverse findings.
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