Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
Membership-consent thresholds for oppression petitions are satisfied by unchallenged voter-list consents, while unsupported forgery claims require pro...
Transfer pricing tolerance rules govern software development and online advertisement support services where the tested party's margins or transaction prices fall within the prescribed range. Foreign exchange gains or losses linked to export invoices may be operating items for IT-enabled services, subject to verification and corresponding treatment in comparable-company margins. Income from sale of SEIS scrips is non-operating because it arises from an incentive scheme rather than service exports, requiring parity adjustments for comparables. Comparable selection requires final search criteria and detailed FAR analysis: companies with negligible IT-enabled services activity may be excluded, while additional or previously selected comparables may be reconsidered. Comparable-margin computations require verification and correct application.
Transfer pricing tolerance rules govern software development and online advertisement support services where the tested party's margins or transaction prices fall within the prescribed range. Foreign exchange gains or losses linked to export invoices may be operating items for IT-enabled services, subject to verification and corresponding treatment in comparable-company margins. Income from sale of SEIS scrips is non-operating because it arises from an incentive scheme rather than service exports, requiring parity adjustments for comparables. Comparable selection requires final search criteria and detailed FAR analysis: companies with negligible IT-enabled services activity may be excluded, while additional or previously selected comparables may be reconsidered. Comparable-margin computations require verification and correct application.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
