SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Upper turnover filters in transfer-pricing comparable selection may be applied where differences in turnover, brand value, economies of scale, bargaining power and ownership of intangibles materially affect profitability and comparability. High-turnover software-development companies were treated as unsuitable comparables because their scale and functional profile differed from that of the tested party. The approach supports excluding enterprises exceeding the stated turnover threshold when scale-related factors distort an arm's-length comparison.
Upper turnover filters in transfer-pricing comparable selection may be applied where differences in turnover, brand value, economies of scale, bargaining power and ownership of intangibles materially affect profitability and comparability. High-turnover software-development companies were treated as unsuitable comparables because their scale and functional profile differed from that of the tested party. The approach supports excluding enterprises exceeding the stated turnover threshold when scale-related factors distort an arm's-length comparison.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
