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...
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.
Note: It is a system-generated summary and is for quick reference only.
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