Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Transfer-pricing analysis for software development and...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any adjustment.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Transfer-pricing analysis for software development and maintenance support services addresses the limits of applying an APA margin outside its covered assessment years. Foreign exchange fluctuation directly linked to those services is treated as operating income. A working-capital adjustment must be considered where supporting workings are furnished, subject to verification, and the resulting comparable margin must be tested against the statutory tolerance range; no adjustment remains if it falls within that range. Comparable-selection issues become academic on that basis. The note also addresses short credit for tax deducted at source, requiring factual verification and fresh adjudication.
Transfer-pricing analysis for software development and maintenance support services addresses the limits of applying an APA margin outside its covered assessment years. Foreign exchange fluctuation directly linked to those services is treated as operating income. A working-capital adjustment must be considered where supporting workings are furnished, subject to verification, and the resulting comparable margin must be tested against the statutory tolerance range; no adjustment remains if it falls within that range. Comparable-selection issues become academic on that basis. The note also addresses short credit for tax deducted at source, requiring factual verification and fresh adjudication.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4786
Join Channel
TaxTMI 
