Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Prospective customs notification amendments cannot bar provisional release consideration for earlier imports when bills of lading predate their commen...
Prescribed transfer-pricing methods must govern arm's length price determination; an ad hoc allocation of consideration between independently negotiated business-transfer and intellectual-property agreements cannot be sustained without comparable analysis, valuation, benchmarking or another recognised methodology. Advertisement, marketing and promotion expenditure alone does not establish economic ownership of marketing intangibles or permit rewriting arm's length agreements absent sham or collusion. The transfer-pricing adjustment was deleted without remand. The dividend distribution tax treaty-rate claim was remitted for action dependent on pending Supreme Court proceedings. Interest for delayed return filing caused by an undisputed e-filing portal glitch was deleted, while the assessment-limitation challenge became infructuous following retrospective amendments.
Prescribed transfer-pricing methods must govern arm's length price determination; an ad hoc allocation of consideration between independently negotiated business-transfer and intellectual-property agreements cannot be sustained without comparable analysis, valuation, benchmarking or another recognised methodology. Advertisement, marketing and promotion expenditure alone does not establish economic ownership of marketing intangibles or permit rewriting arm's length agreements absent sham or collusion. The transfer-pricing adjustment was deleted without remand. The dividend distribution tax treaty-rate claim was remitted for action dependent on pending Supreme Court proceedings. Interest for delayed return filing caused by an undisputed e-filing portal glitch was deleted, while the assessment-limitation challenge became infructuous following retrospective amendments.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
