Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
Provisional attachment fails without material showing likely concealment, transfer, or dealing that could frustrate confiscation of mortgaged property...
Works-contract goods transfers remain outside service tax, while qualifying lift irrigation works receive exemption and extended limitation cannot app...
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 4886 
