Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Under TNMM, advertising, marketing and promotion expenditure included in operating costs cannot be separately benchmarked where inter-linked agency commission, advertising sales and marketing-service transactions have already been accepted at arm's length. A separate method for that horizontal cost item would distort the arm's-length determination; therefore, substantive and protective AMP adjustments were deleted. Whether working-capital adjustments were already reflected in the tested margins and comparable financials must be verified, since that would preclude a separate interest adjustment on outstanding receivables. The Form 26AS income mismatch, including claimed associated-enterprise receipts and mutual-agreement-procedure coverage, requires factual verification with admitted additional evidence. Both verification issues were remitted for fresh decision.
Under TNMM, advertising, marketing and promotion expenditure included in operating costs cannot be separately benchmarked where inter-linked agency commission, advertising sales and marketing-service transactions have already been accepted at arm's length. A separate method for that horizontal cost item would distort the arm's-length determination; therefore, substantive and protective AMP adjustments were deleted. Whether working-capital adjustments were already reflected in the tested margins and comparable financials must be verified, since that would preclude a separate interest adjustment on outstanding receivables. The Form 26AS income mismatch, including claimed associated-enterprise receipts and mutual-agreement-procedure coverage, requires factual verification with admitted additional evidence. Both verification issues were remitted for fresh decision.
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