Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
Customs Broker licence proceedings require accurate procedural facts before delay or natural-justice findings can justify setting aside regulatory act...
Page of 4826
Press 'Enter' after typing page number.
521 to 540 of 96510 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Rule 10B(3) permits reasonably accurate comparability...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitability.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Rule 10B(3) permits reasonably accurate comparability adjustments under TNMM to neutralise material differences affecting profitability; it does not require mathematical precision or publicly available identical capacity-utilisation data for comparables. Extraordinary COVID-19-related underutilisation of a captive service provider's manpower and infrastructure can create abnormal idle costs because fixed employee and infrastructure costs are spread over reduced activity. Where the taxpayer substantiates those costs and their computation, and they are not shown to be non-genuine, non-business-related or incorrect, the costs should be neutralised in determining the arm's length margin. The resulting adjusted margin may establish that the international transaction is at arm's length.
Rule 10B(3) permits reasonably accurate comparability adjustments under TNMM to neutralise material differences affecting profitability; it does not require mathematical precision or publicly available identical capacity-utilisation data for comparables. Extraordinary COVID-19-related underutilisation of a captive service provider's manpower and infrastructure can create abnormal idle costs because fixed employee and infrastructure costs are spread over reduced activity. Where the taxpayer substantiates those costs and their computation, and they are not shown to be non-genuine, non-business-related or incorrect, the costs should be neutralised in determining the arm's length margin. The resulting adjusted margin may establish that the international transaction is at arm's length.
Note: It is a system-generated summary and is for quick reference only.