Withdrawal of obsolete FEMA circulars streamlines rules on external commercial borrowings, non-resident bond investments, and money transfer sub-agent...
Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
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Under the Transactional Net Margin Method, selling commission paid to associated enterprises forms part of the operating cost of the software development services segment when it is closely linked to that segment. Where TNMM is accepted as the most appropriate method and the segment is accepted as arm's length, the commission cannot be isolated for separate benchmarking or assigned a nil arm's-length price after its inclusion in the segmental operating margin. Verification under an appellate direction resulted in deletion of the transfer-pricing adjustment, and the Revenue's challenge to the verification and consequential relief failed.
Under the Transactional Net Margin Method, selling commission paid to associated enterprises forms part of the operating cost of the software development services segment when it is closely linked to that segment. Where TNMM is accepted as the most appropriate method and the segment is accepted as arm's length, the commission cannot be isolated for separate benchmarking or assigned a nil arm's-length price after its inclusion in the segmental operating margin. Verification under an appellate direction resulted in deletion of the transfer-pricing adjustment, and the Revenue's challenge to the verification and consequential relief failed.
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