Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
Transfer-pricing adjustments were properly confined to...
Transfer-pricing adjustments must be confined to international associated-enterprise transactions, while functionally dissimilar comparables remain excluded from benchmarking.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Transfer-pricing adjustments were properly confined to international transactions involving import of raw materials from associated enterprises, as the arm's-length price mechanism applies to those transactions; the restriction was upheld. Functional differences in products, manufacturing activities and raw materials justified exclusion of a proposed comparable, and the High Court declined to reappraise that factual finding under section 260-A. Working-capital adjustment was remitted for verification because supporting particulars had not initially been furnished, with no final determination of entitlement or amount. The foreign-exchange revenue filter was also remitted for reconsideration under a consistent approach after giving the assessee an opportunity. Revenue appeals were dismissed.
Transfer-pricing adjustments were properly confined to international transactions involving import of raw materials from associated enterprises, as the arm's-length price mechanism applies to those transactions; the restriction was upheld. Functional differences in products, manufacturing activities and raw materials justified exclusion of a proposed comparable, and the High Court declined to reappraise that factual finding under section 260-A. Working-capital adjustment was remitted for verification because supporting particulars had not initially been furnished, with no final determination of entitlement or amount. The foreign-exchange revenue filter was also remitted for reconsideration under a consistent approach after giving the assessee an opportunity. Revenue appeals were dismissed.
Note: It is a system-generated summary and is for quick reference only.