said to be closely-linked when they emanate from
a common source being an order/contract/agreement/arrangement
and the nature, characteristics and terms ... transactions are
substantially flowing from the said common source.
First proviso to Section 92C(2) :
"92C(2). The most appropriate method referred
Since all these appeals emanate from common source, they were
heard together and are being disposed of by this common order. We first
take
utilities which are
supplied from a common source which also services areas of the plant
other than R&D may be admissible, provided they
common
administration, he submits that there was no common staff in so far as
workers and employees were concerned and only common premises shared ... batteries on the ground that UPS cannot
function as a source of Uninterrupted Power without the battery and hence
battery is an integral part
transfer pricing analysis.
Where two or more transactions emanate from common source being an order
or contract or an agreement or an arrangement, then such ... characteristic and terms of such
transaction substantially flow from the said common source."
24. It was submitted that the Assessee is a manufacturer
corporate debtor.
(c) If the two entities are operating under common control, the
indicia as given in section ... would cause inter-change of personnel. If there is a common
source of control over both the entities, it cannot be denied that
meters from the poultry farm boundary and
the well is common source of water for both the applicant and the 4th
respondent who has given
royalty are closely inter-linked, interdependent
and flow from a common source. He at the cost of repetition
reiterated that once the net profit margin
account of short deduction of tax at
source on Common Area Maintenance Charges paid amounting
to Rs 18,67,250/- on the basis that said ... account of short deduction of tax at
source on Common Area Maintenance Charges paid amounting
to Rs 18,67,250/- on the basis that said
attributed to various geochemical processes. Stable isotope
systematics study suggest a common source of recharge, which
is predominantly rainwater. The isotope signatures of high
uranium
