Reassessment for unreturned property sales survives where transfer information, non-filing, and unsupported exemption claims establish a prima facie l...
Profit-element taxation limits additions for unaccounted flat-sale receipts and grey-market purchases, while reliable search records support partial a...
Non-participating bidders cannot disturb concluded liquidation sales on speculative prejudice, while costs for such challenges must remain proportiona...
Transfer-pricing benchmarking of software development services applies an employee-cost-to-sales filter within 50% to 80%, requiring recomputation of the arm's length price on that basis. Comparables without segmental results, entities affected by an extraordinary amalgamation, and businesses performing materially different functions are excluded. Overdue associated-enterprise receivables are international transactions, but an interest adjustment under the CUP method requires identified segmental comparables, supporting material, and computation consistent with segmental trends; an unsupported adjustment is deleted. Working-capital differences require fresh examination under applicable transfer-pricing principles.
Transfer-pricing benchmarking of software development services applies an employee-cost-to-sales filter within 50% to 80%, requiring recomputation of the arm's length price on that basis. Comparables without segmental results, entities affected by an extraordinary amalgamation, and businesses performing materially different functions are excluded. Overdue associated-enterprise receivables are international transactions, but an interest adjustment under the CUP method requires identified segmental comparables, supporting material, and computation consistent with segmental trends; an unsupported adjustment is deleted. Working-capital differences require fresh examination under applicable transfer-pricing principles.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
