Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
For arm's length pricing of preform silica imports, the Comparable Uncontrolled Price (CUP) method applies where reliable internal and external uncontrolled-price data exist for the same raw material. Customs data and internal uncontrolled purchases supported that the associated-enterprise purchase price did not exceed uncontrolled prices. In the absence of changes in the transactions, parties or asset base, a consistently accepted CUP method should not be replaced by the Transactional Net Margin Method (TNMM) without justification. Under TNMM, a diversified manufacturer and service provider without reliable segmental revenue or margin data is not functionally comparable to an entity manufacturing only optical fibre. The CUP-based pricing was accepted, and the TNMM-based transfer-pricing adjustment was deleted.
For arm's length pricing of preform silica imports, the Comparable Uncontrolled Price (CUP) method applies where reliable internal and external uncontrolled-price data exist for the same raw material. Customs data and internal uncontrolled purchases supported that the associated-enterprise purchase price did not exceed uncontrolled prices. In the absence of changes in the transactions, parties or asset base, a consistently accepted CUP method should not be replaced by the Transactional Net Margin Method (TNMM) without justification. Under TNMM, a diversified manufacturer and service provider without reliable segmental revenue or margin data is not functionally comparable to an entity manufacturing only optical fibre. The CUP-based pricing was accepted, and the TNMM-based transfer-pricing adjustment was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
