Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
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COVID-19-related fixed overheads incurred during lockdown to retain employees and maintain business continuity were treated as extraordinary, non-operating costs and excluded from the tested party's operating cost for TNMM profitability analysis. Capacity underutilisation may warrant an adjustment; where comparable companies' data is not publicly available, transfer-pricing authorities should obtain it before determining the adjustment. Transfer-pricing adjustments under Chapter X are confined to international transactions with associated enterprises and cannot extend to unrelated-party transactions. Bad-debt double-addition claims require verification where the amount was allegedly already offered to tax. Working-capital adjustments require evidence that differences materially affected price, cost or profits; absent that evidence, reconsideration depends on furnishing supporting particulars.
COVID-19-related fixed overheads incurred during lockdown to retain employees and maintain business continuity were treated as extraordinary, non-operating costs and excluded from the tested party's operating cost for TNMM profitability analysis. Capacity underutilisation may warrant an adjustment; where comparable companies' data is not publicly available, transfer-pricing authorities should obtain it before determining the adjustment. Transfer-pricing adjustments under Chapter X are confined to international transactions with associated enterprises and cannot extend to unrelated-party transactions. Bad-debt double-addition claims require verification where the amount was allegedly already offered to tax. Working-capital adjustments require evidence that differences materially affected price, cost or profits; absent that evidence, reconsideration depends on furnishing supporting particulars.
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