Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Rectification of DRP directions that changed AMP benchmarking from the earlier approach to intensity-adjusted TNMM, on the CIT(DR)'s application, was unsustainable; the rectified directions and consequential assessment order were set aside. Original DRP directions requiring deletion of a protective AMP adjustment bound the assessment proceedings, so the protective adjustment based on the Bright Line Test was also set aside. AMP transfer-pricing adjustments derived through both the Bright Line Test and intensity-adjusted TNMM were unsustainable for the relevant year and corresponding subsequent years. The impugned assessment orders were set aside, while academic, consequential and unpressed grounds remained open or were not pressed.
Rectification of DRP directions that changed AMP benchmarking from the earlier approach to intensity-adjusted TNMM, on the CIT(DR)'s application, was unsustainable; the rectified directions and consequential assessment order were set aside. Original DRP directions requiring deletion of a protective AMP adjustment bound the assessment proceedings, so the protective adjustment based on the Bright Line Test was also set aside. AMP transfer-pricing adjustments derived through both the Bright Line Test and intensity-adjusted TNMM were unsustainable for the relevant year and corresponding subsequent years. The impugned assessment orders were set aside, while academic, consequential and unpressed grounds remained open or were not pressed.
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