Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
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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.
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