Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
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 ...
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 
of 4884 
