Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Page of 4786
Press 'Enter' after typing page number.
601 to 620 of 95714 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Under the combined transaction approach to TNMM, separate benchmarking of royalty and Global Accounts Manager charges is impermissible where those costs are already included in the operating costs of the logistics segment being benchmarked. The transfer pricing adjustments for those items were therefore deleted, consistent with the principle that individual cost elements embedded in an accepted combined segment analysis should not be separately benchmarked without a corresponding cost-base adjustment. Claims concerning TDS credit and errors in computing interest and fees were treated as computational matters requiring verification and were remitted to the Assessing Officer for fresh consideration after providing an opportunity of hearing. The appeal was consequently partly allowed.
Under the combined transaction approach to TNMM, separate benchmarking of royalty and Global Accounts Manager charges is impermissible where those costs are already included in the operating costs of the logistics segment being benchmarked. The transfer pricing adjustments for those items were therefore deleted, consistent with the principle that individual cost elements embedded in an accepted combined segment analysis should not be separately benchmarked without a corresponding cost-base adjustment. Claims concerning TDS credit and errors in computing interest and fees were treated as computational matters requiring verification and were remitted to the Assessing Officer for fresh consideration after providing an opportunity of hearing. The appeal was consequently partly allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4786
Join Channel
TaxTMI 
