Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Related-party customs valuation requires objectively founded reasonable doubt before rejecting the declared transaction value. Non-disclosure of an exporter's Suggested List Price, without evidence that the discount was abnormal, artificial or relationship-driven, does not justify rejection where comparable export-country discounts and commercial normality are established. Any reassessment must follow the prescribed valuation methods sequentially; the residual method cannot use the exporter's domestic-market price. Royalty, technical assistance and know-how fees are includible only when they relate to imported goods and are payable as a condition of sale. Payments for Indian manufacturing technology, and discontinued notional management fees, are therefore excluded absent evidence of import-price adjustment.
Related-party customs valuation requires objectively founded reasonable doubt before rejecting the declared transaction value. Non-disclosure of an exporter's Suggested List Price, without evidence that the discount was abnormal, artificial or relationship-driven, does not justify rejection where comparable export-country discounts and commercial normality are established. Any reassessment must follow the prescribed valuation methods sequentially; the residual method cannot use the exporter's domestic-market price. Royalty, technical assistance and know-how fees are includible only when they relate to imported goods and are payable as a condition of sale. Payments for Indian manufacturing technology, and discontinued notional management fees, are therefore excluded absent evidence of import-price adjustment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
