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...
Foreign-currency loans repayable in US dollars were benchmarked using LIBOR plus 300 basis points rather than a domestic lending rate, and that transfer-pricing direction was sustained. Under TNMM, comparables must satisfy functional and product comparability; sectorally distinct engineering services and aluminium-capacitor manufacturing entities were excluded. No arm's-length interest adjustment applied to delayed associated-enterprise receivables where no interest was charged to either associated or non-associated enterprises and transaction pricing already reflected margins. Expenditure relating to investments could not be disallowed where no exempt dividend income was received or receivable during the year. The assessee's and Revenue's appeals were dismissed.
Foreign-currency loans repayable in US dollars were benchmarked using LIBOR plus 300 basis points rather than a domestic lending rate, and that transfer-pricing direction was sustained. Under TNMM, comparables must satisfy functional and product comparability; sectorally distinct engineering services and aluminium-capacitor manufacturing entities were excluded. No arm's-length interest adjustment applied to delayed associated-enterprise receivables where no interest was charged to either associated or non-associated enterprises and transaction pricing already reflected margins. Expenditure relating to investments could not be disallowed where no exempt dividend income was received or receivable during the year. The assessee's and Revenue's appeals were dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4821 
Join Channel 
