Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Corporate guarantees to subsidiaries are described as shareholder activities but, following retrospective inclusion within capital financing, remain international transactions requiring arm's length benchmarking; the guarantee commission was restricted to 0.5%. Omission without a saving clause of the specified domestic transaction category for related-party expenditure invalidated the related transfer-pricing reference and adjustment. Common head-office costs may be allocated at cost among eligible and non-eligible units because the head office is a cost centre, not an independent service provider. Interest-free advances to overseas associated enterprises require arm's length interest benchmarking despite own funds or commercial expediency. Recurring advertisement, brand-promotion and market-research expenditure was treated as revenue expenditure, not capital expenditure.
Corporate guarantees to subsidiaries are described as shareholder activities but, following retrospective inclusion within capital financing, remain international transactions requiring arm's length benchmarking; the guarantee commission was restricted to 0.5%. Omission without a saving clause of the specified domestic transaction category for related-party expenditure invalidated the related transfer-pricing reference and adjustment. Common head-office costs may be allocated at cost among eligible and non-eligible units because the head office is a cost centre, not an independent service provider. Interest-free advances to overseas associated enterprises require arm's length interest benchmarking despite own funds or commercial expediency. Recurring advertisement, brand-promotion and market-research expenditure was treated as revenue expenditure, not capital expenditure.
Note: It is a system-generated summary and is for quick reference only.
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