Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Gross profit additions on matched purchase-and-sale accommodation entries are unwarranted where the transaction profit has already been recorded and offered to tax. Estimating further profit solely from the purchase side is unsupported when books of account remain unrejected and quantitative records show no discrepancy. A gross profit rate derived from manufacturing activity cannot be applied to trading or accommodation transactions, because manufacturing margins reflect processing, labour and overheads not present in trading. In the absence of evidence of undisclosed procurement or genuine sales supported by unaccounted purchases, no further gross profit estimation is sustainable.
Gross profit additions on matched purchase-and-sale accommodation entries are unwarranted where the transaction profit has already been recorded and offered to tax. Estimating further profit solely from the purchase side is unsupported when books of account remain unrejected and quantitative records show no discrepancy. A gross profit rate derived from manufacturing activity cannot be applied to trading or accommodation transactions, because manufacturing margins reflect processing, labour and overheads not present in trading. In the absence of evidence of undisclosed procurement or genuine sales supported by unaccounted purchases, no further gross profit estimation is sustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4937 
