SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Cost Plus Method based on an internal comparable was treated as the most appropriate method for software development services where identical services were supplied to an independent entity at the same cost-plus mark-up. A traditional pricing method cannot be replaced by a transactional profit method without cogent reasons demonstrating its inadequacy, including proper consideration of the functions, assets and risks analysis. The services were at arm's length and the transfer-pricing adjustment was deleted. No interest adjustment arose on delayed associated-enterprise receivables because interest was not charged on comparable delayed payments by unrelated parties; that adjustment was also deleted.
Cost Plus Method based on an internal comparable was treated as the most appropriate method for software development services where identical services were supplied to an independent entity at the same cost-plus mark-up. A traditional pricing method cannot be replaced by a transactional profit method without cogent reasons demonstrating its inadequacy, including proper consideration of the functions, assets and risks analysis. The services were at arm's length and the transfer-pricing adjustment was deleted. No interest adjustment arose on delayed associated-enterprise receivables because interest was not charged on comparable delayed payments by unrelated parties; that adjustment was also deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
