Revisional jurisdiction over export quota premium deductions requires both error and Revenue prejudice; a permissible assessment view cannot be displa...
Final benami adjudication bars contradictory tax-evasion prosecution where settlement findings confirm full disclosure and cooperation without conceal...
Faceless assessment and registration procedures are updated through electronic communication, revised recovery rules, extended deadlines, and replacem...
Risk-based selective vessel boarding requires accurate declarations and preserves master and agent liability where physical inspections are not select...
Consistent treatment of depreciation in calculating the profit level indicator under the Transactional Net Margin Method is necessary for a valid arm's-length comparison. Including depreciation in an assessee's operating cost while excluding it from comparable companies' operating costs produces an anomalous comparison and can distort the assessed margin. Recomputing the assessee's margin without depreciation, consistently with the comparables, placed the international transactions with associated enterprises at arm's length. The resulting arm's-length price adjustment and related addition were deleted.
Consistent treatment of depreciation in calculating the profit level indicator under the Transactional Net Margin Method is necessary for a valid arm's-length comparison. Including depreciation in an assessee's operating cost while excluding it from comparable companies' operating costs produces an anomalous comparison and can distort the assessed margin. Recomputing the assessee's margin without depreciation, consistently with the comparables, placed the international transactions with associated enterprises at arm's length. The resulting arm's-length price adjustment and related addition were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4884 
