Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4884 
