Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Transfer pricing treatment of idle capacity, comparables,...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on evidence.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Transfer pricing treatment of idle capacity, comparables, segmental results and customs duty requires fresh examination using cost-audit data, customer agreements, available comparability material and supporting evidence. Provision write-backs and miscellaneous receipts may remain operating items where the original provisions were operating expenses, subject to verification; where business support income is non-operating, corresponding costs must also be excluded from margins. Exchange loss on borrowings for domestic capital assets after the asset is put to use is revenue in character, as section 43A applies to assets acquired outside India. Software applications qualify for computer-rate depreciation, and secondment reimbursements of actual salary costs are not fees for technical services where employees work under the recipient's control and salary tax is deducted.
Transfer pricing treatment of idle capacity, comparables, segmental results and customs duty requires fresh examination using cost-audit data, customer agreements, available comparability material and supporting evidence. Provision write-backs and miscellaneous receipts may remain operating items where the original provisions were operating expenses, subject to verification; where business support income is non-operating, corresponding costs must also be excluded from margins. Exchange loss on borrowings for domestic capital assets after the asset is put to use is revenue in character, as section 43A applies to assets acquired outside India. Software applications qualify for computer-rate depreciation, and secondment reimbursements of actual salary costs are not fees for technical services where employees work under the recipient's control and salary tax is deducted.
Note: It is a system-generated summary and is for quick reference only.