Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing benchmarking had to be confined to the assessee's international transactions where segmental results for associated enterprise and non-associated enterprise dealings were available and capable of segregation. Entity-level margins could not be used merely because the segmental accounts were unaudited, and the benchmarking was therefore directed to be on segmental profitability. In applying external TNMM, comparables had to satisfy functional, asset and risk similarity; retail businesses, fabric or yarn manufacturers, contract socks manufacturers, leather garment manufacturers, and companies with merger or acquisition during the year were excluded, and exporters with export revenue below 75% of sales were also filtered out. The TPO was directed to redo comparability analysis and allow the +/- 5% tolerance under section 92C(2).
Transfer pricing benchmarking had to be confined to the assessee's international transactions where segmental results for associated enterprise and non-associated enterprise dealings were available and capable of segregation. Entity-level margins could not be used merely because the segmental accounts were unaudited, and the benchmarking was therefore directed to be on segmental profitability. In applying external TNMM, comparables had to satisfy functional, asset and risk similarity; retail businesses, fabric or yarn manufacturers, contract socks manufacturers, leather garment manufacturers, and companies with merger or acquisition during the year were excluded, and exporters with export revenue below 75% of sales were also filtered out. The TPO was directed to redo comparability analysis and allow the +/- 5% tolerance under section 92C(2).
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