Effective hearing in GST adjudication requires actual opportunity to respond; ineffective service through a former auditor invalidated ex parte procee...
Third-party search material requires special assessment route, rendering general reassessment notices without jurisdiction when it forms the proceedin...
Transfer-pricing adjustments must be confined to international associated-enterprise transactions, while functionally dissimilar comparables remain ex...
Insolvency moratorium bars income-tax revision proceedings against corporate debtors until the moratorium ends, preserving merits for later determinat...
Under the transactional net margin method, turnover disparity...
Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal operating costs.
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
Under the transactional net margin method, turnover disparity alone does not justify excluding a functionally comparable entity; material impact or reasonably accurate comparability adjustments must be examined, and arm's-length-price adjustments must be confined to associated-enterprise transactions. Goodwill amortisation that is abnormal and non-recurring, and costs unrelated to associated-enterprise transactions, are excluded from operating costs. Import-duty adjustments and warranty, replacement and bad-debt deductions were accepted on consistent treatment, while verification-dependent provision reversals, write-backs and working-capital adjustments require factual examination. Long-term benefit alone does not make business-rights expenditure capital, and an appellate authority may admit a fresh deduction claim for verification. Depreciation on capitalised software expenditure was allowed.
Under the transactional net margin method, turnover disparity alone does not justify excluding a functionally comparable entity; material impact or reasonably accurate comparability adjustments must be examined, and arm's-length-price adjustments must be confined to associated-enterprise transactions. Goodwill amortisation that is abnormal and non-recurring, and costs unrelated to associated-enterprise transactions, are excluded from operating costs. Import-duty adjustments and warranty, replacement and bad-debt deductions were accepted on consistent treatment, while verification-dependent provision reversals, write-backs and working-capital adjustments require factual examination. Long-term benefit alone does not make business-rights expenditure capital, and an appellate authority may admit a fresh deduction claim for verification. Depreciation on capitalised software expenditure was allowed.
Note: It is a system-generated summary and is for quick reference only.