Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
COVID-19 adjustments in transfer-pricing benchmarking require proof of exceptional pandemic expenditure, its non-operating character, and a materially different impact on comparables; pandemic timing alone is insufficient. TNMM also requires consistent treatment of operating and non-operating items for the tested party and comparables, including foreign-exchange effects from revenue transactions and depreciation on business assets. Internal CUP for software support services requires transaction-level comparability of contractual scope, functions, assets, risks, personnel, volume, duration and market conditions, with reliable adjustments for material differences. Transfer-pricing adjustments were remanded for fresh verification and benchmarking. A final assessment following timely draft assessment and DRP directions remains within the separate DRP-related limitation period.
COVID-19 adjustments in transfer-pricing benchmarking require proof of exceptional pandemic expenditure, its non-operating character, and a materially different impact on comparables; pandemic timing alone is insufficient. TNMM also requires consistent treatment of operating and non-operating items for the tested party and comparables, including foreign-exchange effects from revenue transactions and depreciation on business assets. Internal CUP for software support services requires transaction-level comparability of contractual scope, functions, assets, risks, personnel, volume, duration and market conditions, with reliable adjustments for material differences. Transfer-pricing adjustments were remanded for fresh verification and benchmarking. A final assessment following timely draft assessment and DRP directions remains within the separate DRP-related limitation period.
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