Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
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.