Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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Internal comparables under the transactional net margin method should generally be preferred to external comparables where audited segmental accounts reliably distinguish associated-enterprise and non-associated-enterprise transactions. Segmental financials extracted from audited accounts may support arm's length price determination where a chartered accountant certifies both their mathematical accuracy and allocation on a generally accepted rational basis. A claim that segmental data were not maintained is unsustainable when the relevant segmental figures are demonstrably derived from audited accounts.
Internal comparables under the transactional net margin method should generally be preferred to external comparables where audited segmental accounts reliably distinguish associated-enterprise and non-associated-enterprise transactions. Segmental financials extracted from audited accounts may support arm's length price determination where a chartered accountant certifies both their mathematical accuracy and allocation on a generally accepted rational basis. A claim that segmental data were not maintained is unsustainable when the relevant segmental figures are demonstrably derived from audited accounts.
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