Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
AE segmental benchmarking under TNMM requires consideration of segmental results included in the transfer-pricing study and certified information furnished before completion of the transfer-pricing assessment. Neither the Act nor the Rules requires audited segmental accounts; where the AE-segment margin falls within the arm's-length range of selected comparables, rejection on conjectural grounds is unwarranted and the related adjustment is deleted. Ind AS presentation of part of compulsorily convertible debentures as equity does not change their underlying debt character before actual conversion or redemption. Interest remains deductible in principle, subject to verification that no conversion or redemption occurred during the relevant year.
AE segmental benchmarking under TNMM requires consideration of segmental results included in the transfer-pricing study and certified information furnished before completion of the transfer-pricing assessment. Neither the Act nor the Rules requires audited segmental accounts; where the AE-segment margin falls within the arm's-length range of selected comparables, rejection on conjectural grounds is unwarranted and the related adjustment is deleted. Ind AS presentation of part of compulsorily convertible debentures as equity does not change their underlying debt character before actual conversion or redemption. Interest remains deductible in principle, subject to verification that no conversion or redemption occurred during the relevant year.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
