Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Separate transfer-pricing adjustment for notional interest on delayed trade receivables from associated enterprises is not warranted where the taxpayer is completely debt-free and bears no interest cost on borrowings, because delayed collection creates no additional financing burden. Debt-free status requires verification from financial statements and other relevant records. If verified, the adjustment for interest on outstanding receivables is deleted. This approach applies across the assessment years concerned.
Separate transfer-pricing adjustment for notional interest on delayed trade receivables from associated enterprises is not warranted where the taxpayer is completely debt-free and bears no interest cost on borrowings, because delayed collection creates no additional financing burden. Debt-free status requires verification from financial statements and other relevant records. If verified, the adjustment for interest on outstanding receivables is deleted. This approach applies across the assessment years concerned.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
