Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
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Management support services supported by agreements, invoices, allocation records, presentations, e-mails and time sheets were treated as genuine business services, not mere stewardship or shareholder activities, so the arm's length price could not be fixed at nil without applying a recognised transfer pricing method. In the manufacturing segment, TNMM analysis showed the tested party's operating margin remained higher than the corrected comparable margin, so no transfer pricing adjustment could survive. The appellate deletion of both adjustments was sustained.
Management support services supported by agreements, invoices, allocation records, presentations, e-mails and time sheets were treated as genuine business services, not mere stewardship or shareholder activities, so the arm's length price could not be fixed at nil without applying a recognised transfer pricing method. In the manufacturing segment, TNMM analysis showed the tested party's operating margin remained higher than the corrected comparable margin, so no transfer pricing adjustment could survive. The appellate deletion of both adjustments was sustained.
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