Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Functional comparability under TNMM for licence fees paid by a limited-risk distributor of licensed film and television content turns on functions, assets, risks, contractual terms and reliable financial data, rather than product similarity alone. Software and hardware distributors may therefore be valid comparables despite distributing different products. A revenue split under the Other Method requires comparable uncontrolled transactions, reliable market evidence or another objective economic basis to quantify contributions; allocated functional weightages alone cannot establish an arm's length price.
Functional comparability under TNMM for licence fees paid by a limited-risk distributor of licensed film and television content turns on functions, assets, risks, contractual terms and reliable financial data, rather than product similarity alone. Software and hardware distributors may therefore be valid comparables despite distributing different products. A revenue split under the Other Method requires comparable uncontrolled transactions, reliable market evidence or another objective economic basis to quantify contributions; allocated functional weightages alone cannot establish an arm's length price.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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