Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
Jurisdictional facts in certificate-of-origin discrepancies can support customs show-cause proceedings, leaving factual explanations for departmental ...
Closely linked international transactions benchmarked together...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional claims remain permissible.
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
Closely linked international transactions benchmarked together under TNMM should not be selectively segregated for separate testing where the aggregated approach has been accepted for other transactions. Intra-group service payments require evidence of services and benefits, and their arm's length price cannot be treated as nil under CUP without a comparable uncontrolled transaction. The notes also address deletion of a fixed-asset purchase mark-up adjustment through consistency with an earlier year. The dividend distribution tax treaty-rate claim was remitted pending resolution of the underlying legal issue. An additional refund claim may be raised before appellate authorities without filing a revised return, for determination of correct tax liability.
Closely linked international transactions benchmarked together under TNMM should not be selectively segregated for separate testing where the aggregated approach has been accepted for other transactions. Intra-group service payments require evidence of services and benefits, and their arm's length price cannot be treated as nil under CUP without a comparable uncontrolled transaction. The notes also address deletion of a fixed-asset purchase mark-up adjustment through consistency with an earlier year. The dividend distribution tax treaty-rate claim was remitted pending resolution of the underlying legal issue. An additional refund claim may be raised before appellate authorities without filing a revised return, for determination of correct tax liability.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4786
Join Channel
TaxTMI 
