Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
A modified return filed by a successor following an NCLT-approved business reorganisation must be examined within the scope of the reorganisation order for recomputation of income. Under MAT, transfer pricing adjustments under normal provisions cannot increase book profit unless authorised by a specified adjustment to certified accounts. For transfer pricing, closely linked software sales and support services may be aggregated under TNMM where they form an integrated business model; documented evidence of service rendition and benefit precludes a nil valuation. A foreign associated enterprise may be the tested party if it is the least complex entity, and comparable margins require appropriate period and segmental-data analysis.
A modified return filed by a successor following an NCLT-approved business reorganisation must be examined within the scope of the reorganisation order for recomputation of income. Under MAT, transfer pricing adjustments under normal provisions cannot increase book profit unless authorised by a specified adjustment to certified accounts. For transfer pricing, closely linked software sales and support services may be aggregated under TNMM where they form an integrated business model; documented evidence of service rendition and benefit precludes a nil valuation. A foreign associated enterprise may be the tested party if it is the least complex entity, and comparable margins require appropriate period and segmental-data analysis.
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