Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deduct...
Strict construction of customs exemptions denied concession for brake components, while limitation restricted differential duty to timely Bills of Ent...
Way Leave Permissions cannot be retrospectively revived through insolvency plans, and affected infrastructure holders require safety review and hearin...
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 4894 
