Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination b...
Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
Service of notice and contractual debt acknowledgment preserved insolvency admission against a corporate guarantor despite limitation and natural just...
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.
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