While "Lucille" and "Emanuella" are not names of the primary legal parties, they appear to be associated with specific case summaries or instructional documents found in shared educational repositories related to this ruling. Core Legal Concept: Transfer Pricing Comparability The case at 95 ITR (Trib) 0350 focuses on the technical application of Rule 10CA(2)
: There are various Caribbean cases involving the name "Emmanuel" (e.g., Emmanuel v Emmanuel in St. Lucia or Emanuel v Lawrence trib 0350 lucille vs emanuella