Prior APA methodology guides transfer pricing benchmarking where consistent FAR profiles support comparability and arm's length margins eliminate adju...
Battery-integrated tablet rear covers classify as lithium-ion accumulators when protective components enable the battery's active energy-storage funct...
Return-processing adjustments cannot disallow diminution in the value of a business-purpose investment in a wholly owned subsidiary solely because a tax audit report describes it as capital expenditure where binding jurisdictional precedent permits an analogous business loss. Once an intimation is issued after considering the taxpayer's response, the Centralised Processing Centre performs a quasi-judicial function and must follow binding High Court law. Failure to consider a jurisdictional High Court decision delivered before the intimation, and specifically raised in a rectification application, constitutes a mistake apparent from the record. The resulting disallowance requires rectification in accordance with that precedent.
Return-processing adjustments cannot disallow diminution in the value of a business-purpose investment in a wholly owned subsidiary solely because a tax audit report describes it as capital expenditure where binding jurisdictional precedent permits an analogous business loss. Once an intimation is issued after considering the taxpayer's response, the Centralised Processing Centre performs a quasi-judicial function and must follow binding High Court law. Failure to consider a jurisdictional High Court decision delivered before the intimation, and specifically raised in a rectification application, constitutes a mistake apparent from the record. The resulting disallowance requires rectification in accordance with that precedent.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4884 
