Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
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...
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Selection of the most appropriate method for product replacement services supplied at nil sale price depends on the taxpayer's functional profile. Where the taxpayer acts only as a service provider and custodian of imported spares, without setting resale prices, selecting customers, or bearing attendant risks, TNMM applies rather than RPM for arm's-length price recomputation. Comparable selection for benchmarking those services is governed by settled transfer-pricing principles and does not raise a substantial question of law. The erstwhile five per cent tolerance range must be considered when recomputing the arm's-length price in accordance with applicable judicial principles.
Selection of the most appropriate method for product replacement services supplied at nil sale price depends on the taxpayer's functional profile. Where the taxpayer acts only as a service provider and custodian of imported spares, without setting resale prices, selecting customers, or bearing attendant risks, TNMM applies rather than RPM for arm's-length price recomputation. Comparable selection for benchmarking those services is governed by settled transfer-pricing principles and does not raise a substantial question of law. The erstwhile five per cent tolerance range must be considered when recomputing the arm's-length price in accordance with applicable judicial principles.
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