Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
Transfer-pricing comparability under the Transactional Net Margin Method may apply a turnover ceiling where it rests on a rational and logical basis, despite no prescribed turnover filter. Comparable entities must be closely aligned in functions, assets and risks because enterprise size and significant turnover differences can affect pricing. A software-product developer that owns intellectual property or develops and markets products is functionally distinct from a captive software-development service provider developing solely for its associated enterprise. Where the final comparable set has been determined, remand may be confined to reconsideration of identified exclusions rather than requiring a wholly fresh arm's-length-price exercise.
Transfer-pricing comparability under the Transactional Net Margin Method may apply a turnover ceiling where it rests on a rational and logical basis, despite no prescribed turnover filter. Comparable entities must be closely aligned in functions, assets and risks because enterprise size and significant turnover differences can affect pricing. A software-product developer that owns intellectual property or develops and markets products is functionally distinct from a captive software-development service provider developing solely for its associated enterprise. Where the final comparable set has been determined, remand may be confined to reconsideration of identified exclusions rather than requiring a wholly fresh arm's-length-price exercise.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
