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 ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
