Section 153C requires person-specific search authority and year-specific incriminating material for unabated assessments while preventing unsupported ...
Equivalent-value attachment can reach pre-existing assets, but jointly owned property remains protected beyond the accused's attributable proceeds of ...
A prior Advance Pricing Agreement remains persuasive for...
Prior APA methodology guides transfer pricing benchmarking where consistent FAR profiles support comparability and arm's length margins eliminate adjustment.
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
A prior Advance Pricing Agreement remains persuasive for transfer pricing benchmarking outside its covered years where the transaction and functions, assets and risks profile continue; departure requires material differences in those factors or economic circumstances. In software-distribution comparability, functional similarity takes priority over turnover, and turnover-based exclusion requires a demonstrated material effect on operating margins. Comparable companies with related-party transactions exceeding the applicable threshold cannot reliably serve as uncontrolled benchmarks without demonstrable adjustments. Under TNMM, no transfer pricing adjustment is warranted where the tested party's operating margin falls within the applicable arm's length range after the comparable set is finalised.
A prior Advance Pricing Agreement remains persuasive for transfer pricing benchmarking outside its covered years where the transaction and functions, assets and risks profile continue; departure requires material differences in those factors or economic circumstances. In software-distribution comparability, functional similarity takes priority over turnover, and turnover-based exclusion requires a demonstrated material effect on operating margins. Comparable companies with related-party transactions exceeding the applicable threshold cannot reliably serve as uncontrolled benchmarks without demonstrable adjustments. Under TNMM, no transfer pricing adjustment is warranted where the tested party's operating margin falls within the applicable arm's length range after the comparable set is finalised.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
