Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Transfer pricing adjustments on intra-group management charges were deleted after accepting the assessee's TNMM benchmarking and rejecting a nil arm's length value. Royalty on sales was restricted by allowing 5% on both sales to associated enterprises and third parties, as the authorities could not disallow the entire payment or treat the assessee as a contract manufacturer for this purpose. For outstanding receivables, working capital adjustment had to be given first; only any remaining shortfall could be examined again for interest adjustment, so the issue was restored for fresh determination. Disallowance of employees' PF and ESI contribution deposited after the welfare law due date was sustained, as later payment within the income-tax filing timeline did not cure the default.
Transfer pricing adjustments on intra-group management charges were deleted after accepting the assessee's TNMM benchmarking and rejecting a nil arm's length value. Royalty on sales was restricted by allowing 5% on both sales to associated enterprises and third parties, as the authorities could not disallow the entire payment or treat the assessee as a contract manufacturer for this purpose. For outstanding receivables, working capital adjustment had to be given first; only any remaining shortfall could be examined again for interest adjustment, so the issue was restored for fresh determination. Disallowance of employees' PF and ESI contribution deposited after the welfare law due date was sustained, as later payment within the income-tax filing timeline did not cure the default.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
