Reversal write-backs, foreign exchange losses, and secondment reimbursements are non-taxable, while transfer pricing adjustments require re-examination.
Reversal write-backs, foreign exchange losses, and secondment reimbursements are non-taxable, while transfer pricing adjustments require re-examination. Issue Whether capacity utilization/economic adjustments under TNMM can be summarily rejected by the TPO without considering past coordinate bench precedents. Whether provisions created in earlier years and treated as operating expenses can be treated as non-operating income upon write-back… Read More »