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Under TNMM, audited annual accounts and reports provide a...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins fall within range.
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Under TNMM, audited annual accounts and reports provide a reliable basis for comparability analysis over unaudited raw data. Verified working-capital-adjusted margins must reflect differences between tested international transactions and comparable uncontrolled transactions; where the taxpayer's margin falls within that range, no transfer-pricing adjustment is warranted. A claimed duplicate disallowance of interest on income tax requires verification whether a voluntary disallowance was already made in the return; any repeated disallowance must be deleted. Employees' provident fund contributions are deductible only if deposited by the due date under the relevant fund law, requiring verification.
Under TNMM, audited annual accounts and reports provide a reliable basis for comparability analysis over unaudited raw data. Verified working-capital-adjusted margins must reflect differences between tested international transactions and comparable uncontrolled transactions; where the taxpayer's margin falls within that range, no transfer-pricing adjustment is warranted. A claimed duplicate disallowance of interest on income tax requires verification whether a voluntary disallowance was already made in the return; any repeated disallowance must be deleted. Employees' provident fund contributions are deductible only if deposited by the due date under the relevant fund law, requiring verification.
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