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...
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.