GST payment representations require record-based, reasoned decisions while substantive entitlement remains open for determination by competent authori...
Reassessment sanction under extended limitation required approval from the competent specified authority, invalidating proceedings approved by an inco...
Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
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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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