Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
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Transfer-pricing comparability must meet statutory requirements; taxpayer-selected comparables cannot be replaced merely with a standard departmental set. Functional dissimilarity, abnormal margins, turnover, contractual risk profile and related-party transactions may justify exclusion, with a lower related-party threshold preferred where adequate uncontrolled comparables exist. Foreign-exchange gains or losses are operating items only when directly linked to the relevant international transaction. Reliable subsequently available data may support appellate-stage comparable changes, subject to statutory conditions. The prescribed variation is a tolerance range, not a standard deduction. Working-capital adjustment addresses material margin differences rather than selecting comparables. Comparable-selection burdens rest on the party making the relevant assertion, and cross-objections are unavailable in appeals under section 260A.
Transfer-pricing comparability must meet statutory requirements; taxpayer-selected comparables cannot be replaced merely with a standard departmental set. Functional dissimilarity, abnormal margins, turnover, contractual risk profile and related-party transactions may justify exclusion, with a lower related-party threshold preferred where adequate uncontrolled comparables exist. Foreign-exchange gains or losses are operating items only when directly linked to the relevant international transaction. Reliable subsequently available data may support appellate-stage comparable changes, subject to statutory conditions. The prescribed variation is a tolerance range, not a standard deduction. Working-capital adjustment addresses material margin differences rather than selecting comparables. Comparable-selection burdens rest on the party making the relevant assertion, and cross-objections are unavailable in appeals under section 260A.
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