Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
In transfer pricing benchmarking, the turnover filter and broad functional comparability were treated as relevant comparability criteria under TNMM. A diagnostics company was validly excluded because its turnover fell below the modified range, and earlier-year inclusion did not control since each year must be tested on its own facts. A separate glassware and laboratory-products company was also excluded because its product mix and customer profile were not broadly comparable to medical devices used in patient treatment. Subvention receipts under the distribution arrangement were held to reduce operating cost, not form part of operating revenue, so the assessee's operating margin was correctly taken at 5.04%.
In transfer pricing benchmarking, the turnover filter and broad functional comparability were treated as relevant comparability criteria under TNMM. A diagnostics company was validly excluded because its turnover fell below the modified range, and earlier-year inclusion did not control since each year must be tested on its own facts. A separate glassware and laboratory-products company was also excluded because its product mix and customer profile were not broadly comparable to medical devices used in patient treatment. Subvention receipts under the distribution arrangement were held to reduce operating cost, not form part of operating revenue, so the assessee's operating margin was correctly taken at 5.04%.
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