Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Pure cost-to-cost reimbursements for IT infrastructure and software support, seconded employee salaries, and travel costs were treated as non-income items, not fees for technical, managerial, or consultancy services, so no withholding obligation arose and the related disallowances were deleted. On receivables, the text states that where the advance pricing agreement did not fix a specific date for applying prevailing LIBOR, the assessee's use of publicly available six-month USD LIBOR was accepted and the transfer pricing adjustment for delayed realisation of invoices was set aside.
Pure cost-to-cost reimbursements for IT infrastructure and software support, seconded employee salaries, and travel costs were treated as non-income items, not fees for technical, managerial, or consultancy services, so no withholding obligation arose and the related disallowances were deleted. On receivables, the text states that where the advance pricing agreement did not fix a specific date for applying prevailing LIBOR, the assessee's use of publicly available six-month USD LIBOR was accepted and the transfer pricing adjustment for delayed realisation of invoices was set aside.
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