Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Transfer pricing comparables for basic market research and testing services turned on functional comparability and related party screening. India Tourism Development Corporation Ltd. was retained as a comparable, while Unimed Diagnostics Private Limited, Medall Healthcare Private Limited, IGT Solutions Private Limited and Fuzen Software Private Limited were treated as functionally dissimilar because their business models differed from information-gathering and data-compilation services. The note also records that depreciation on computer software and disallowance of international travel expenses were sent back for fresh verification because the DRP directions had not been properly implemented.
Transfer pricing comparables for basic market research and testing services turned on functional comparability and related party screening. India Tourism Development Corporation Ltd. was retained as a comparable, while Unimed Diagnostics Private Limited, Medall Healthcare Private Limited, IGT Solutions Private Limited and Fuzen Software Private Limited were treated as functionally dissimilar because their business models differed from information-gathering and data-compilation services. The note also records that depreciation on computer software and disallowance of international travel expenses were sent back for fresh verification because the DRP directions had not been properly implemented.
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