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...
Safe Harbour Rules could not be applied suo motu to rework segmental trading costs where the assessee had not opted for that regime and had furnished segmental accounts with allocation keys; the Assessing Officer/Transfer Pricing Officer was directed to adopt the assessee's allocation after verification. An arm's length price of nil for intra-group services was also rejected because the Other Method requires a comparable uncontrolled transaction, which was not shown, and the services had already been aggregated and benchmarked under TNMM, making a separate adjustment a double count. The same reasoning invalidated the lumpsum licence fee adjustment and separate benchmarking of trademark fee. The penalty challenge was dismissed as premature.
Safe Harbour Rules could not be applied suo motu to rework segmental trading costs where the assessee had not opted for that regime and had furnished segmental accounts with allocation keys; the Assessing Officer/Transfer Pricing Officer was directed to adopt the assessee's allocation after verification. An arm's length price of nil for intra-group services was also rejected because the Other Method requires a comparable uncontrolled transaction, which was not shown, and the services had already been aggregated and benchmarked under TNMM, making a separate adjustment a double count. The same reasoning invalidated the lumpsum licence fee adjustment and separate benchmarking of trademark fee. The penalty challenge was dismissed as premature.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
