Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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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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