TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins fall within range.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....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.....