Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
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...
TNMM benchmarking required exclusion of functionally dissimilar, diversified, and unsegmented companies from the comparable set for manufacturing and engineering-estimation segments. Intra-group support-service charges required fresh verification of evidence showing benefits received and benchmarking under TNMM; the issue was remanded. Business-connected reversals, miscellaneous income, foreign-exchange gains and export incentives were treated as operating income where related expenditure had been treated as operating, increasing the profit level indicator. In the extraordinary COVID-affected year, current-year margins of final comparables were required for comparison rather than weighted averages including normal years. Interest on overdue associated-enterprise receivables was not imputable where audited accounts showed the taxpayer was debt-free and lease liabilities were not borrowings.
TNMM benchmarking required exclusion of functionally dissimilar, diversified, and unsegmented companies from the comparable set for manufacturing and engineering-estimation segments. Intra-group support-service charges required fresh verification of evidence showing benefits received and benchmarking under TNMM; the issue was remanded. Business-connected reversals, miscellaneous income, foreign-exchange gains and export incentives were treated as operating income where related expenditure had been treated as operating, increasing the profit level indicator. In the extraordinary COVID-affected year, current-year margins of final comparables were required for comparison rather than weighted averages including normal years. Interest on overdue associated-enterprise receivables was not imputable where audited accounts showed the taxpayer was debt-free and lease liabilities were not borrowings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
