Territorial jurisdiction for money-laundering trials is revised for specified districts, replacing earlier court-area entries under the statutory fram...
Retrospective amendments to the Dispute Resolution Panel...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tolerance-band verification.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Retrospective amendments to the Dispute Resolution Panel procedure and assessment-limitation provisions, effective from 1 April 2009, place the final assessment order within the applicable limitation period. Transfer pricing adjustments require consideration of a pending rectification application concerning implementation of Dispute Resolution Panel directions. Software development comparables require reliable contemporaneous information, functional similarity and clear segmental data; entities with mixed functions, absent segmental disclosure or unreliable public information are unsuitable. For IT-enabled services, comparability depends on the relevant-year operating segment and service profile, while separately reported IT-enabled services segments may be considered. Distribution transactions qualify for the statutory tolerance band only after verification of wholesale-trading conditions and the permitted arm's-length-price variation. Penalty challenges confined to initiation remain premature.
Retrospective amendments to the Dispute Resolution Panel procedure and assessment-limitation provisions, effective from 1 April 2009, place the final assessment order within the applicable limitation period. Transfer pricing adjustments require consideration of a pending rectification application concerning implementation of Dispute Resolution Panel directions. Software development comparables require reliable contemporaneous information, functional similarity and clear segmental data; entities with mixed functions, absent segmental disclosure or unreliable public information are unsuitable. For IT-enabled services, comparability depends on the relevant-year operating segment and service profile, while separately reported IT-enabled services segments may be considered. Distribution transactions qualify for the statutory tolerance band only after verification of wholesale-trading conditions and the permitted arm's-length-price variation. Penalty challenges confined to initiation remain premature.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
