TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Functional comparability governs selection of software development support service comparables. Entities undertaking enterprise transformation, software-product or diversified activities, onsite services, product development or research and development, without reliable segmental information, do not meet the benchmark for routine software development support services and are excluded. The functional profiles of two proposed comparables require fresh examination. Inclusion of another comparable depends on verification of its related-party transaction computation under the applicable filter. Weighted-average operating margins and working-capital adjustments for software development and sales and marketing support services require verification and recomputation. Slump-sale gains and employee-benefit deduction claims also require factual verification, with interest and penalty issues following consequentially.
Functional comparability governs selection of software development support service comparables. Entities undertaking enterprise transformation, software-product or diversified activities, onsite services, product development or research and development, without reliable segmental information, do not meet the benchmark for routine software development support services and are excluded. The functional profiles of two proposed comparables require fresh examination. Inclusion of another comparable depends on verification of its related-party transaction computation under the applicable filter. Weighted-average operating margins and working-capital adjustments for software development and sales and marketing support services require verification and recomputation. Slump-sale gains and employee-benefit deduction claims also require factual verification, with interest and penalty issues following consequentially.
Note: It is a system-generated summary and is for quick reference only.