Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
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...
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.
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