Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Segmental aggregation under TNMM prevents a separate nil arm's length price adjustment for intra-group back-office, sales and marketing support services that are integral operating costs of subscription and services segments under an assured-margin model; a separate adjustment would duplicate the segment-level benchmarking. Working capital adjustment must be allowed where differing working-capital levels materially affect comparable margins, despite unavailable daily public balances, subject to verification. Comparable selection requires functional similarity: product developers, education providers, companies with proprietary products or intangibles, diversified operations, entrepreneurial risks, or absent segmental data should be excluded from routine service-provider benchmarks. TDS credit must be allowed, interest under section 234A is not leviable on the stated facts, and consequential tax computation is required.
Segmental aggregation under TNMM prevents a separate nil arm's length price adjustment for intra-group back-office, sales and marketing support services that are integral operating costs of subscription and services segments under an assured-margin model; a separate adjustment would duplicate the segment-level benchmarking. Working capital adjustment must be allowed where differing working-capital levels materially affect comparable margins, despite unavailable daily public balances, subject to verification. Comparable selection requires functional similarity: product developers, education providers, companies with proprietary products or intangibles, diversified operations, entrepreneurial risks, or absent segmental data should be excluded from routine service-provider benchmarks. TDS credit must be allowed, interest under section 234A is not leviable on the stated facts, and consequential tax computation is required.
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