Government water works contract GST concession applied before its withdrawal, while contractual tax reimbursement claims lay outside advance-ruling sc...
Stamp valuation increases after registration-fee payment led to deletion of property-purchase addition within tolerance and without valuation referral...
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 4891 
