Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
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Business dependence on regulatory affairs and compliance processes established an associated-enterprise relationship, which was sustained because the relationship had also been accepted in transfer-pricing documentation. Foreign associated-enterprise selection as the tested party was rejected where reliable foreign comparable data was not readily accessible and geographical and economic conditions differed; the assessee was retained as the tested party. Domain-specific regulatory affairs services were not treated as KPO services merely by reference to the Rule 10TA definition, and comparables from diverse R&D, engineering, IT, advertising and gaming activities were unsuitable. Fresh benchmarking and comparable selection were directed in line with the assessee's FAR profile after a hearing opportunity.
Business dependence on regulatory affairs and compliance processes established an associated-enterprise relationship, which was sustained because the relationship had also been accepted in transfer-pricing documentation. Foreign associated-enterprise selection as the tested party was rejected where reliable foreign comparable data was not readily accessible and geographical and economic conditions differed; the assessee was retained as the tested party. Domain-specific regulatory affairs services were not treated as KPO services merely by reference to the Rule 10TA definition, and comparables from diverse R&D, engineering, IT, advertising and gaming activities were unsuitable. Fresh benchmarking and comparable selection were directed in line with the assessee's FAR profile after a hearing opportunity.
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