Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
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 4897 
