Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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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