Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Prospective customs notification amendments cannot bar provisional release consideration for earlier imports when bills of lading predate their commen...
Arm's-length pricing of interest on 30-year non-convertible debentures cannot rest on an unsupported minimum-tenure filter under the comparable uncontrolled price method, particularly where tenure does not uniformly determine coupon rates; the transfer-pricing adjustment was deleted. Interest limitation for debt payable to non-resident associated enterprises must exclude interest paid to non-associated enterprises and prevent duplicate disallowance of interest already affected by transfer pricing; recomputation and consequential relief were directed. Classification of assessment adjustments under the appropriate head of income requires verification of the computation and records. A challenge to penalty initiation is premature where no final penalty order is under appeal.
Arm's-length pricing of interest on 30-year non-convertible debentures cannot rest on an unsupported minimum-tenure filter under the comparable uncontrolled price method, particularly where tenure does not uniformly determine coupon rates; the transfer-pricing adjustment was deleted. Interest limitation for debt payable to non-resident associated enterprises must exclude interest paid to non-associated enterprises and prevent duplicate disallowance of interest already affected by transfer pricing; recomputation and consequential relief were directed. Classification of assessment adjustments under the appropriate head of income requires verification of the computation and records. A challenge to penalty initiation is premature where no final penalty order is under appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
