Belated Form 10B filing during Covid-19 cannot defeat charitable exemption where genuine hardship warrants condonation and substantial justice prevail...
Limitation for consequential assessments runs from prescribed authority receipt, while verified purchases cannot be disallowed merely for unanswered s...
Higher depreciation for qualifying commercial vehicles, exempt-income disallowance, research deduction verification, and club-expense treatment clarif...
Charitable registration renewal cannot become an assessment of receipts, profitability or annual exemption compliance, requiring renewal and donation ...
AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
Captive contract software-development services are benchmarked against companies performing comparable software-development functions, assets and risks; product-development businesses, complex digital-product providers and companies lacking relevant segmental information are unsuitable. Companies earning software-development service revenue may remain comparable where no material functional difference is established, while entities exceeding the applicable related-party transaction filter must be excluded. Where delayed trade receivables arise solely from the service transaction benchmarked under TNMM, they require combined benchmarking. Working-capital adjustment for material differences subsumes the receivables effect, so separate notional interest is unwarranted. Financials of an unverified proposed comparable require verification against applicable filters, and assessed income should be rectified using correct figures.
Captive contract software-development services are benchmarked against companies performing comparable software-development functions, assets and risks; product-development businesses, complex digital-product providers and companies lacking relevant segmental information are unsuitable. Companies earning software-development service revenue may remain comparable where no material functional difference is established, while entities exceeding the applicable related-party transaction filter must be excluded. Where delayed trade receivables arise solely from the service transaction benchmarked under TNMM, they require combined benchmarking. Working-capital adjustment for material differences subsumes the receivables effect, so separate notional interest is unwarranted. Financials of an unverified proposed comparable require verification against applicable filters, and assessed income should be rectified using correct figures.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
