Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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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